1) You still have to conform to the Interagency Appraisal Guidelines.
2) There will not be a Regulation B requirement after 1/18/14 for notices or appraisal copies for junior-lien secured loans.
3) However, there remains the matter of the HPML appraisal requirement under Reg Z 1026.35(c). If the loan in question is closed-end and secured by the consumer's principal dwelling, and otherwise fits the definition of an HPML at 1026.35(a)(1) for a junior lien-secured loan, the appraisal requirements of section .35(c) will apply.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8