Re-post of a prior question

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  • #3998

    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?
    September 17, 2013 at 10:01 pm #3963

    KeymasterThe 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.
    September 26, 2013 at 11:06 am #3980

    ParticipantI 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?


    Yes, effective January 18, 2014, the ECOA Valuations Rule does not cover second liens and other subordinate loans and loans that are not secured by a dwelling (such as loans secured solely by land).

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