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#2113389 - 01/06/17 07:35 PM Loan Assumption
banker-12 Offline
Diamond Poster
Joined: May 2007
Posts: 1,243
Is the Regulation B Appraisal rule required on loan assumptions? We have a loan that is being assumed by a new borrower, we are not ordering a new appraisal. should we provide the appraisal notice and a copy of the appraisal to the new borrowers?

The assumption is not increasing the loan amount or extending the term. We think it is required because the notice is provided “in connection with an application for credit that is secured by a first lien on a dwelling”. We have an application for credit because it is a new transaction with new borrowers.

thanks,

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2113459 - 01/07/17 03:15 PM Re: Loan Assumption banker-12
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,361
Galveston, TX
I would say that it would be required.
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#2114152 - 01/13/17 02:36 PM Re: Loan Assumption banker-12
Jen J Offline
100 Club
Joined: Dec 2015
Posts: 144
Per 1002.14(a), aren't the delivery and disclosure requirements only applicable for "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"? (Emphasis mine.)

Since no appraisal is being developed in conjunction with this application, it doesn't appear that it would apply.

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