September 26, 2013 at 11:06 am EDT
#3980
Anonymous
Inactive
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?