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.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com