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#2273347 - 07/25/22 04:58 PM Collateral Substitution Open End LOC
Love those Regs Offline
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Joined: Apr 2002
Posts: 296
Southern State
If we have an existing line of credit secured by multiple 1st lien properties and we do a collateral substitution and add a new 1st lien dwelling, do we have to provide the appraisal application notice? On open-end lines, the regulation says, before account opening and this is not account opening - that occurred long ago.
Last edited by Love those Regs; 07/25/22 04:59 PM.
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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2273348 - 07/25/22 06:02 PM Re: Collateral Substitution Open End LOC Love those Regs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
A substitution of collateral is not usually precipitated by an application for credit.

1002.14—Rules on providing appraisals and other valuations.
(a) Providing appraisals and other valuations. (1) In general. A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit ..................
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