So, if the creditor knows it won't be developing a new appraisal for the purpose of the renewal, the notice isn't required. I'd add that, if the creditor later decides it needs a fresh valuation before approving the renewal, you will need to provide that copy of the valuation/appraisal. And that's why a lot of lenders go the "give the notice anyhow" route.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8