Under the new Appraisal Rules, when we renew a loan for which we have an existing appraisal, how do the rules apply? Are we required to provide to the borrower a copy of the appraisal that we have in file?
Reg B OSC 1002.14(a)(1)(2) states: 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.
There is no exemption from the HPML appraisal requirements for renewals.