ECOA and your appraisal: the valuation copy a conventional borrower is owed before closing

On a first-lien conforming loan, Reg B gives you a copy of every written valuation — including the property data report behind an appraisal waiver — promptly and at least three business days before closing, plus a decision within 30 days.

Valuations you must receive, waiver or not

The Regulation B valuations rule applies to any first-lien loan secured by a dwelling, so every conforming purchase and refinance is in scope. Within three business days of application you get a notice of your right to copies; the copies themselves are due promptly after completion and no later than three business days before consummation. “Valuation” means any written estimate of value the lender develops — a full appraisal, a desk review, an AVM output and, when DU or LPA grants value acceptance with property data, the property data collection report. Lenders sometimes treat a waiver as “no appraisal, nothing to send”; the rule says otherwise. You may waive the three-day timing, but the documents must still be in your hands at or before closing.

What the copy lets a move-up buyer do

Reading the appraisal before closing is how you catch a value below contract price in time to invoke an appraisal contingency, request a reconsideration of value under the GSE rules, or renegotiate. It is also the only way to see whether the appraiser used the right comparables for a larger or unusual home. The lender may charge a reasonable fee for the appraisal itself, but not for the copy.

Co-borrowers, spouses and who has to sign

A common Reg B issue on repeat purchases: lenders asking a non-applicant spouse to sign the note. The creditor may require the spouse’s signature on the security instrument in community-property and certain other states to perfect the lien, but may not require the spouse to become a co-obligor when the applicant qualifies alone. Conversely, if you and a partner apply jointly, both of you must affirmatively indicate intent to apply jointly — the checkbox on the Uniform Residential Loan Application exists for that reason.

Income the lender cannot discount, and the 30-day clock

Retirement, child support, alimony and public-assistance income must be considered if you choose to disclose them, and age may not be used against an applicant of any age who has capacity to contract. A decision — approval, counteroffer or written denial with specific reasons — is due within 30 days of a completed application. On an AUS-driven conforming file, an “Approve/Ineligible” finding followed by silence is a frequent failure; after 30 days you are entitled to a written adverse action notice naming the reasons, such as DTI, insufficient reserves or an unacceptable property type.

What to check

• Ask for the appraisal, desk review, AVM or property data report as soon as it is complete — all are “valuations” under Reg B.
• Do not sign a waiver of the three-day appraisal timing unless you have already read the valuation.
• A non-applicant spouse may need to sign the mortgage, not the note, when you qualify alone — push back on extra co-obligors.
• After 30 days without a decision, request the written adverse action notice; the stated reasons tell you what to fix for the next application.

Frequently asked questions

My loan got an appraisal waiver — do I still get anything under ECOA?

If the lender produced no written valuation at all, there is nothing to deliver. But when value acceptance comes with a property data collection, or the lender runs an AVM or review, those are written valuations and copies are due promptly and before closing. Ask the lender directly whether any valuation document exists in the file.

Can a lender ignore my spouse’s pension when we apply for a conforming loan?

No. Regulation B requires the creditor to consider reliably continuing income from pensions, annuities and Social Security when the applicant discloses it, and the GSE guides accept it with award letters or bank statements. The lender may verify continuance for three years, but may not refuse to count it because of its source or the recipient’s age.

The rule in full: Equal Credit Opportunity Act (ECOA) and Regulation B. The borrower profile: Conventional loan borrowers. Related guides: Conventional loan requirements: credit, down payment, DTI, reserves, property · Conforming loan limits: how the FHFA number works and what happens above it · Credit score needed to buy a house: minimums by loan type, and what it costs to be average · Debt-to-income ratio limits by loan type — and how to lower yours.

Other federal rules for conventional loan borrowers

TILA / Reg Z · RESPA · TRID disclosures · Fair Housing Act · HMDA · SAFE Act / NMLS · ATR / QM · HOEPA · HPA / PMI · Servicing rules · FCRA · Flood insurance · MARS rule · SCRA · LO compensation

ECOA for other borrowers

First-time buyers · Veterans · Self-employed · Investors · Retirees · Bad credit · Foreign nationals · Physicians · Heroes · Rural buyers · Condo & second home · Refinancing