A loan customer has notified us today they have been diagnosed with covid-19. We recently had an appraiser in their home home two weeks ago. Are we allowed to notify the appraiser of their possible exposure?

Given the potential HIPPA risks I would not specify which customer unless they provided you with consent to share their information. Has the appraiser performed other appraisals so that they wouldn't know the identity of the person?

If not, I'd be obtaining consent from your customer in writing and before proceeding at all, discussing with legal counsel.

Much like Reg P, there is no private cause of action in HIPPA. I am not even so sure the disclosure would be covered under HIPPA. Is the bank a covered entity in this scenario? It seems unlikely.

Generally even an employer/employee relationship is only covered if there is the existence of a health plan.

If the customer reached out to you directly, I would say all is fair.

if it has been fewer than 14 days since the appraiser was in the home, I would simply notify the appraiser that they have been potentially exposed based on information provided to the bank, suggest they get tested, also don't let them perform any more appraisals until the 14-day quarantine period is up, and leave it at that.