I see in Reg B and it's commentary that you don't have to comply with the requirements of 1002.14(a)(1) if you have a renewals and aren't getting a new appraisal valuation. (a)(1) is the requirement to give the appraisal.

What I don't see is that you don't have to comply with (a)(2) which is providing the disclosure notice. In a renewal transaction where we know there isn't going to be a new appraisal/valuation do we still have to give the disclosure notice?

I started to reply with a "that's what the rule says." But here's the thing -- Section (a)(1) does not apply "to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request." [Comment 14(a)(1)-2]. And paragraph 1002.14(a)(2) only applies to "applications subject to paragraph (a)(1)." So I think you can justify not sending the notice if you know that there will not be an appraisal or valuation done.

However, if you decide during the process that you need to update the values, then you'll need to send the notice and comply with the copy delivery requirements.

I have not cleared my "read" of the regulatory language with anyone from the Bureau.

That makes sense now that you point it out and I agree. 1002.14(a)(2) only needs to be complied with for transactions subject to 1002.14(a)(1). Therefore, no new appraisal/valuation, then it appears (a)(2) would be a moot issue.