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#2239624 - 07/15/20 04:16 PM Appraisal Notification for Business Purpose Loans
Annie Offline
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Joined: Sep 2018
Posts: 27
In the following situation, would a lender be required to send the appraisal disclosure required by Reg. B 1002.14(a)(2)?the

Applicant is an LLC and is purchasing a property and land which most recently were used as a dwelling. The applicant intends to use the property and land for business purpose. The dwelling will be used as office space for the business.

Does the current or last use of the property or the intended use of the property dictate the disclosure requirement?

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#2239629 - 07/15/20 04:58 PM Re: Appraisal Notification for Business Purpose Loans Annie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,310
Galveston, TX
All you have to go on is the definition of a dwelling:

1002.14(b)(2) Dwelling. The term "dwelling" means a residential structure that contains one to four units whether or not that structure is attached to real property.

It either is or it is not.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2239653 - 07/15/20 10:25 PM Re: Appraisal Notification for Business Purpose Loans Annie
Annie Offline
Junior Member
Joined: Sep 2018
Posts: 27
Thank you for the additional information. However, I'd like clarify. The building itself will not be a dwelling after the loan closes as it will be used as a business premises. Are you saying that because the structure could be used as a dwelling, it is a dwelling? Or are you saying that because it's a dwelling at the time of application, it is a dwelling?

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#2239654 - 07/16/20 12:15 AM Re: Appraisal Notification for Business Purpose Loans Annie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,310
Galveston, TX
What I am saying is that you have to make the call. There is no other real guidance. It is like everything else that is borderline - just give them the dang notice and a copy of the appraisal then there can be no arguments.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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