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If we complete a change in terms for a HELOC to change the maturity to a future date, and complete this prior to the HELOC maturity, and we obtain an appraisal, does the Reg B appraisal rule apply? Are we required to provide a copy of the appraisal on a 1st lien on a dwelling 3 days prior to a change in terms?
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Based on the commentary regarding renewals, I believe intent is to provide a copy of any appraisal/valuation you have done in connection with that credit decision. So, I would say yes, you would need to comply with the Reg B appraisal/valuation rules.
2. Renewals. Section 1002.14(a)(1) applies when an applicant requests the renewal of an existing extension of credit and the creditor develops a new appraisal or other written valuation. Section 1002.14(a)(1) does not apply to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request.
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