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#2132484 - 05/31/17 03:30 PM Appraisal notice
banker-12 Offline
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We have a loan secured by a house that is used like an apartment building. It contains 12 bedrooms for college students, like a fraternity house. The appraisal was done as a multi family; is the appraisal notice required?

Thanks

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2132527 - 05/31/17 06:09 PM Re: Appraisal notice banker-12
banker-12 Offline
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it's a two story building with actually 17 bedrooms (not 12) used as student housing. We feel the appraisal requirements do not apply since it's being used as a transitory housing. is this correct?

thanks,

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#2132538 - 05/31/17 06:38 PM Re: Appraisal notice banker-12
rlcarey Online
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rlcarey
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Galveston, TX
It doesn't fit:

The term "dwelling" means a residential structure that contains one to four units whether or not that structure is attached to real property.
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#2132550 - 05/31/17 07:05 PM Re: Appraisal notice banker-12
banker-12 Offline
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Okay thank you. Some were thinking it did apply because there is only one kitchen used by everyone living there.

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#2250255 - 03/09/21 05:11 PM Re: Appraisal notice banker-12
Compliance504 Offline
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Tennessee
Hey Randy...I need some help understanding the term dwelling for Reg B.....

We have a similar loan for a ministry that will be secured by 3 houses that will be used as transitory residences ....each house will provide transitory residence for 8 people....

Two questions:
Does transitory come into play for Reg B's dwelling definition...Reg B does not exclude transitory like HMDA specifically does?

For Reg B...does it matter how a residential structure will be used....if a one unit house is going to house 8 people....that doesn't matter does it? It matters what the structure actually is....is that correct?

Any help explaining this would be appreciated....
Last edited by Compliance504; 03/09/21 05:13 PM.
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#2250256 - 03/09/21 05:16 PM Re: Appraisal notice banker-12
Compliance504 Offline
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Tennessee
I can't edit my post....I wanted to include that I think this is covered by Reg B because transitory is not excluded and the structure itself is a dwelling regardless of how many people will live in it....

I need to know if I'm on track or way off.....

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#2250257 - 03/09/21 05:37 PM Re: Appraisal notice banker-12
rlcarey Online
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rlcarey
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Galveston, TX
I think you understand. If it is a 1-4 family dwelling - what it is used for and how many people may live in it is not pertinent to Regulation B
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#2250289 - 03/09/21 10:12 PM Re: Appraisal notice banker-12
Compliance504 Offline
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Posts: 729
Tennessee
Thanks, Randy.....

I've been informed that it is actually a 3 unit building that will provide transitory residence....I still think it applies because its a 1-4 unit residence...do you agree?

I know in a situation where we aren't sure it's best just to follow the rule.....but I just want to make sure I understand this....

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#2250297 - 03/09/21 11:45 PM Re: Appraisal notice banker-12
rlcarey Online
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rlcarey
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Posts: 83,358
Galveston, TX
Agreed.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2250311 - 03/10/21 04:53 PM Re: Appraisal notice banker-12
Compliance504 Offline
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Joined: Dec 2008
Posts: 729
Tennessee
Thanks so much, Randy!

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