I have a couple of questions about Regulation B appraisal rule changes.
1. I know that the changes are for first lien for business or consumer purpose loans. However, what is done with subordinate liens? Are there any requirements for this?
2. Has a definition for business day be set by Reg B?
Regulation B does not have appraisal rules for subordinate lien transactions. But remember if the transaction is a higher priced mortgage loan under regulation Z you have a very similar requirement to provide a notice regarding the appraisal and to give a copy of the appraisal that applies to both first and subordinate lien transactions.