Great question as this can be quite confusing. In short, the answer is yes. The re-validation is new and the customer has not yet received a copy, so they should be provided with one. The preamble to the final rule talks about this in a round about way, but here is what the commentary says:
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.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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