If we use an existing appraisal for a new loan, would we be required to provide a copy of the appraisal to the borrower? The appraisal wouldn't have been "developed" for this particular transaction but it would have been used for it.

Commentary to Reg B:

2. Renewals. Section 1002.14(a)(1) applies when an applicant requests the renewal of an existing extension of credit and the creditor develops a new appraisal or other written valuation. Section 1002.14(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.

This would not be a renewal. It's a whole new loan - does that make a difference?

I see nothing that speaks to that exact situation in the commentary; it is allowed under the appraisal rules, of course, but not addressed for B. I might just send it rather than have to argue.

While I agree that it might be best to just provide the copy, you already know it's not required, precisely because the appraisal was not developed in connection with the request.

I agree, but I have always looked at things like this as: I am talking about giving out a photocopy in a one off situation. How much time will be spent wondering if it is necessary and discussing it with auditors and examiners, vs giving the copy and saying here is another copy of the original appraisal.

We agree. I'm just saying that omitting the copy would not be a compliance problem.

Further question - First loan Consumer - P&I - Closed-End - Second Loan HELOC - closed within 2 months of each other.... re-using the appraisal from the first loan for the HELOC loan - 1) Appraisal Notice required on the HELOC? 2) Appraisal Copy delivery required on the HELOC?

I'm assuming the HELOC is secured by a subordinate lien on the dwelling, thus the answer to both questions is No.

(a) Providing appraisals and other valuations. (1) In general. A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling. A creditor shall provide a copy of each such appraisal or other written valuation promptly upon completion, or three business days prior to consummation of the transaction (for closed-end credit) or account opening (for open-end credit), whichever is earlier. An applicant may waive the timing requirement in this paragraph (a)(1) and agree to receive any copy at or before consummation or account opening, except where otherwise prohibited by law. Any such waiver must be obtained at least three business days prior to consummation or account opening, unless the waiver pertains solely to the applicant's receipt of a copy of an appraisal or other written valuation that contains only clerical changes from a previous version of the appraisal or other written valuation provided to the applicant three or more business days prior to consummation or account opening. If the applicant provides a waiver and the transaction is not consummated or the account is not opened, the creditor must provide these copies no later than 30 days after the creditor determines consummation will not occur or the account will not be opened.