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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Opinions are mine and subject to change frequently