Answer:
Yes, you must provide a copy of that version of the appraisal, notwithstanding the fact that it does not change the appraised value.
Here's why:
1. Regulation B Comment 14(a)(1)-7 (Multiple versions of appraisals or valuations) states "... the reference to 'all' appraisals and other written valuations does not refer to all versions of the same appraisal or other valuation. If a creditor has received multiple versions of an appraisal or other written valuation, the creditor is required to provide only a copy of the latest version received. If, however, a creditor already has provided a copy of one version of an appraisal or other written valuation to an applicant, and the creditor later receives a revision of that appraisal or other written valuation, then the creditor also must provide the applicant with a copy of the revision to comply with § 1002.14(a)(1)."
2. Comment 14(a)(1) (Waiver), paragraph ii, states "... if, within three business days of consummation or account opening, the applicant provides the creditor an affirmative oral or written statement waiving the timing requirement under this rule and the waiver pertains solely to the applicant's receipt of a copy of an appraisal or other written valuation that contains only clerical changes from a previous version of the appraisal or other written valuation provided to the applicant three or more business days prior to consummation or account opening. For purpose of this second type of waiver, revisions will only be considered to be clerical in nature if they have no impact on the estimated value, and have no impact on the calculation or methodology used to derive the estimate. In addition, under § 1002.14(a)(1) the applicant still must receive the copy of the revision at or prior to consummation or account opening"
The requirement applies even to updates to an appraisal of which the applicant has already received a copy, even if the update is only a clerical change. Furthermore, you are required to provide the copy of the updated appraisal document promptly upon acceptance and at least three business days before closing unless the applicant provides you, within three business days before closing, a written waiver of the timing requirement.
If you get that written waiver, you can provide the copy at the closing.
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