I see that the new rules in 1002.14 replace the current rules, and the new rules apply only to 1st lien 1-4 family dwelling secured loans. Does this mean that there is no appraisal disclosure or appraisal providing reg B rule applicable to subordinate lien 1-4 family dwelling secured loans?
I came to this forum to ask the exact same question. Robin – I agree with your answer but I don’t think it addresses the precise question. Since the current requirement under Reg B for appraisals is for all loans secured by a dwelling, and the new Reg B section 14 only addresses loans secured by a first lien, does that mean that we will no longer have appraisal requirements (under Reg B) for subordinate liens?