[kmeade]

Consumer purpose, first mortgage on a single-family dwelling that is the consumer primary residence and is a higher priced loan. Also, taking a first mortgage on 150 acres of land with no structures with a separate deed. I know we must give the borrower a copy of the appraisal on their primary dwelling three day before closing (in hand) but are we also required to give a copy of the appraisal on the land three days before closing (in hand)?

[rcooper]

I believe you would need to supply a copy of the appraisal pertaining to the land. It could be argued that it isn’t required under the HPML rules, because those rules are specifically talking about appraisals of the structure. However, under Reg B you must provide an applicant a copy of all appraisals/valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling. Since this loan will be secured by a first lien on the dwelling and it says “all” I believe it should be given.

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