OK, so to take the cross collateralization question a step further ~ we do cross collateralization for many loans. I am thinking the Reg. B rule is triggered per property, not per loan in these cases. For example: if we are doing a renewal on a loan in February and do an evaluation, we need to deliver that valuation. Then if we do a renewal of another loan which uses that same property as collateral in March and another evaluation is completed, we would then need to deliver that "new" valuation as well.
This has been a lively topic of discussion here in our shop and am hoping I can get some direction. Thanks!