Would providing the borrower/purchaser with a copy of the banks “acquisition appraisal” at time of foreclosure satisfy the new appraisal regulations under REG B and HPML? I would think not, but need some guidance.
I apologize we missed your question. I’m sure you found your answer, but I believe you are correct – IMO the acquisition appraisal would not satisfy the HPML “flip” appraisal requirement. There isn’t a requirement in Reg B to perform an appraisal, but there are delivery requirements for appraisals and valuations.