There are two regulatory requirements for providing an appraisal notice.
• Regulation B requires an appraisal notice for an application for credit secured by a first lien on a dwelling whether the credit is for a business purpose or a consumer purpose.
• Section 1026.35(c)(2) (Higher Priced Mortgage Loans) requires an appraisal notice for a closed-end consumer credit transaction secured by the consumer’s principal dwelling with an APR that exceeds the average prime offer rate by the applicable threshold.
It appears the HPML rule does not apply to your transaction, since your transaction is a business purpose transaction.
It appears the Regulation B requirement does apply to your transaction. It appears your bank is in the first lien position; no other creditor has an interest in the property.