In case of a first mortgage and a simultaneous second mortgage, an appraisal is always developed for the first mortgage and then relied upon for the simultaneous second. Do I understand it correctly that the valuation-delivery requirement does not apply where a creditor uses a written valuation that was “previously developed in connection with [a] prior extension of credit.”?

Take a step back from the question and look at the requirement in 1002.14. It applies to credit that is to be secured by a first lien on a dwelling. Now that you've read that requirement, you've answered your own question.

Also make sure your loan doesn't trigger the HPML appraisal rules.

Yes, if the junior-lien loan is closed-end, it might trigger HPML status (1026.35(a)(1)(iii)). That would make it likely that an appraisal under 1026.35(c) will be required. That also includes an appraisal copy and notice.

Thank you. Really appreciate the 'stepping back" comment!

I have found that the sheer complexity of Regulation Z -- particularly the newer parts of it -- can often be overwhelming, and it can be easy to get so "into" the individual requirements that it sometimes helps to back up a few steps to make sure one hasn't taken the wrong turn in the maze.

I have a follow-up question on this previous thread. If a junior-lien HPML loan is done simultaneously with a first mortgage, are we required to send the same appraisal separately for each loan if it was relied upon for both loans? Similarly, do you believe we would be required to obtain two separate waivers of the timeframe for providing the appraisal prior to closing?

You didn't ask, but I will note here that you only need to supply the Reg B appraisal copy notice once, since that satisfies the notice requirement in Reg. Z 1026.35(c)(5).

Next, and perhaps obvious, the one appraisal developed for the application would have to satisfy the more demanding requirements for the HPML appraisal.

As to sending two copies of the same appraisal, I believe that sending one copy satisfies both requirements. Just be certain to document that you sent it.

As to the waiver question, you would not be able to accept any waiver, since there is no waiver permitted under the HPML appraisal rule.

Thank you for your reply. We were getting two requirements confused (again!) and thank you for the reminder on the fact that there is no waiver ability on the HPML appraisal timing.