If the HELOC is secured by a first lien, then delivery would be required. It is not required on any 2nd lien loan outside of the HPML requirements.
Deliver Copy of Appraisal on HELOC?
The Reg. B requirement to deliver a copy of the appraisal is limited to first lien loans. The Reg. Z appraisal requirement is for HPML loans, and QM loans are exempt. Is there any requirement to deliver a copy of the appraisal on a HELOC or a fixed rate second lien mortgage loan that is not a non-QM HPML loan?
First published on 07/29/2018