[April]

We are refinancing a mortgage loan and instead of ordering a new appraisal we are using the one that was done for the original loan. Would we need to do a second appraisal checklist and appraisal disclosures?

[rcooper]

You would need to give the disclosures. I am not sure I’m understanding your question about the second appraisal checklist, but I believe you are asking if you need to complete the checklist for the appraisal. If this is an HPML you would need to determine if the appraisal meets the requirements for HPMLs and the checklist we provided is a way to do that. Also, the loan may qualify for the refinancing exception under the HPML appraisal rules; even if it does there are still disclosure and delivery requirements under Reg B.

[Author]

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