We have a separate builder services department where they finance residential builders who do both spec and custome homes. The commentary to Reg B indicates that the requirement to provide the appraisal notice applies to both business and consumer purpose loans. Is there anything that would exempt the builder construction loans from this requirement. I could not find anything but our prior compliance officer permitted that procedure and he was very knowledable. I am trying to substaniate an exemption to the appraisal notice requirement for residential builders. Can anyone send me to the appropriate site and/or provide any advice on this issue?

To the best of my knowledge there is no exemption from providing the notice when the loan will be secured by a 1-4 dwelling other than for routinely providing copies of the appraisal to the applicant/borrower. And the definitions of an applicant and person (as I read them) will not grant an exemption either.

I know of no exemptions either....