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Borrower Valuation Delivery System

CoesterVMS developed the Borrower Valuation Delivery System to assist its clients in maintaining compliance with the Consumer Finance Protection Bureau amendment to Regulation B of the Equal Credit Opportunity Act (ECOA). The update, effective January 18th, 2014, generally requires the following:

Creditors to provide to applicants free copies of all appraisals and other written valuations developed in connection with an application for a loan to be secured by a first lien on a dwelling, and require creditors to notify applicants in writing that copies of appraisals will be provided to them promptly.

The Borrower Valuation Delivery System requires borrowers follow a two-step authorization process while providing client users a robust monitoring system, including a delivery queue and manageable notifications, to ensure timely, documented delivery to borrowers.

AUTHORIZATION PROCESS

Beyond language regarding the timeliness of delivery, the Regulation B amendment also requires borrowers give prior consent to electronic delivery of appraisal documents.

As such, the CoesterVMS Borrower Valuation Delivery System employs a two-step authentication process, detailed in the workflow below, requiring borrowers authorize email delivery:

BORROWER DELIVERY QUEUE

The Borrower Delivery Queue assists lenders in monitoring the stage of delivery from the Cloud Control System. Users can access the queue (given sufficient credentials, detailed in Managing User Access below), by selecting the option on the left hand side of the main page.

The following screen will display all deliveries within the past thirty (30) days and allow users to search for specific files or the filter by status and date:

DELIVERY CERTIFICATE

Upon confirmation of delivery, the system generates a certificate confirming the date of electronic delivery.  Click here to download a sample.

DELIVERY INITIATION OPTIONS

CoesterVMS systems will initiate borrower delivery immediately upon completion by default. The options below allow clients to customize the timing of initiation based on their preferences and processes. 

BORROWER DELIVERY DELAY

This option allows clients to temporarily postpone borrower delivery to afford their staff time to review the appraisal report and associated documents prior to delivery to the borrower. Clients may choose to delay borrower deliver at hourly intervals up to 72 hours from completion of the order. Once selected time frame has elapsed, the system will automatically initiate delivery. CoesterVMS systems also afford an option to halt delivery of a report if the report is no longer in completed status at the close of the delay time frame.

SEND NOW OPTIONS

Clients who prefer to review the appraisal prior to initiation of borrower delivery may request CoesterVMS enable the Send Now option on their account. When enabled, the feature queues records until a client staff member manually initiate delivery.

For further information on the BVDS, click here to download the complete user guide