[TheBank]

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?

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[rcooper]

The Reg B appraisal and valuation delivery rules apply to first liens on a dwelling. However, there are rules for providing an appraisal disclosure and a copy of the appraisal for HPML’s in 1026.35 which would apply to subordinate liens on the consumer’s principal dwelling. https://www.ecfr.gov/cgi-bin/text-idx?SID=7f4eca7c248c25d4dfbb06e5f05f0f71&node=20130213y1.44

[Anonymous]

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?

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