You are only required to give the Reg B valuation/appraisal notice on loans secured by a first lien on a dwelling. There are HPML appraisal rules that also require a disclosure – this could include loans secured by a junior lien as well as first liens. If you have a loan that is covered by both the Reg B valuation rule and the HPML appraisal rule you can satisfy both disclosure requirements by providing the Reg B appraisal notice.
