If we are using an appraisal from a prior transaction, would we still need to provide a copy to the applicant on the new transaction? Would the term "developed" mean we would not be required to since it was not "developed" for this particular transaction? I think we should be providing it, however, I am getting some push back on a finding I had on an internal loan review.

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.

I agree with Dan that it's not required, but it seems like operationally it would be easier to just provide it as part of the standard workflow.

But that would obviously depend on the size and complexity of the bank.

Perhaps, fmissle. However, your applicant might wonder why you bothered to send the same appraisal copy twice.

True as well.

You could not be criticised by an examiner for sending a second copy of the same appraisal.

Oh ye of little faith. I'm sure they could criticize us for that somehow.

Something like "Safety and soundness concern due to failure to control costs when making copies of appraisals when not required by regulation, and incurring unnecessary postage costs for mailing them to borrower, for total unnecessary cost of $4.73. 12 CFR § 1002.14(a)."

There you go!