There seems to be a recommendation by more than one regulator that banks make applicants aware of their right to dispute the valuation on the appraisal they receive and the process to do so. There was a mention to add it to one's applicable LOB page on their website or having it disclosed somehow via a document during the disclosure process or when ordering the appraisal. I am interested in everyone's feedback and what they are doing to address this, if anything. Also, is there anything in the regulations that would keep us from just adding it to the Appraisal Disclosure? While I know there are required elements to this disclosure, are we kept from adding anything else?

Thanks ahead of time for your sharing...

I can't answer what other banks are doing, but there can be times you will use an appraisal, but it will not be subject to the Reg B requirement and therefore the (2nd lien loan as an example) borrower may not get the notice.