The argument (from a loan officer, of course) is that the notice must be given during the application process but no later than when the credit decision is made.....so, there is no structure to appraise.....no formal appraisal.
I argue that the Reg defines an "appraisal report" as the document relied upon by a creditor in evaluating the value of a dwelling. So, whatever value was used in order to decide whether or not to make the loan (that is......what is the value of the house going to be and does the loan request fit in the boundaries of the bank's loan policy)must be made available to the applicant upon request. Thus, the notice is required.
Any further opinions on this issue?
The more you sweat in training, the less you bleed in battle.......