Would we have to provide to an applicant an appraisal that was requested by an Investor used only by the Investor...not the creditor?

Differing opinions here at the bank.....

Why would you dismiss the investor as a creditor?

(l) Creditor means a person who, in the ordinary course of business, regularly participates in a credit decision, including setting the terms of the credit. The term creditor includes a creditor's assignee, transferee, or subrogee who so participates. For purposes of §§1002.4(a) and (b), the term creditor also includes a person who, in the ordinary course of business, regularly refers applicants or prospective applicants to creditors, or selects or offers to select creditors to whom requests for credit may be made. A person is not a creditor regarding any violation of the Act or this part committed by another creditor unless the person knew or had reasonable notice of the act, policy, or practice that constituted the violation before becoming involved in the credit transaction. The term does not include a person whose only participation in a credit transaction involves honoring a credit card.

If the investor requested the appraisal in connection with the application for credit I would say you owe the applicant a copy of that appraisal.

Thank you, Dan!!

Carefully note that Regulation B's definition of "creditor" is broader than the Regulation Z definition. And if you're looking at a Reg B requirement, it's the Reg B definition that matters.

Yes, thank you, John, didn't cross my mind to look at the definitions until Dan brought it to my attention.....a good basic reminder for me!!! THANKS!!!!!!