How do the appraisal notice rules apply to Commercial Lines of Credit. The Reg B definition seems to indicate that draws on existing lines of credit are not considered an "application." So, in working with a developer that is building dwellings, if they apply for the initial LOC and there are dwellings secured as part of the initial extension of credit, then the lender would be required to provide the notice and the appraisal per Reg. B? However, if no dwelling initially secures the line or the line is existing and a developer is taking draws on it, then there is no "application" and thus the ECOA appraisal rule does not apply? Is there any exemption for a certain amount of dwellings securing a loan? So, if there are 15 dwellings securing a loan, is it required to abide by the ECOA Appraisal requirements, as long as no other exemption applies?