"The new ECOA Valuations Rule amends the appraisal provisions of ECOA’s Regulation B. It updates current ECOA rules to say that you must provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations, developed in connection with the application
, whether or not the applicants request copies."
My thoughts are, no you would not provide a copy, because the appraisal was not obtained in connection with an application. The loan has already been consummated, so there is no way you can send it "promptly upon completion, but no later than 3 days prior to consummation" CFPB Equal Credit Opportunity Act (ECOA) Valuations Rule - Small Entity Compliance Guide
I know it says "Small Entity" but this appears to be geared toward organizations (of any size) that originate open-end or closed-end loans secured by first liens on dwellings.
I am interested in others thoughts on this as well.