Question - Under the recent final rule amending the appraisal requirements of Regulation B, we understand that the rule applies to first lien mortgage loans secured by a dwelling, and that home equity lines of credit (HELOCs) would only be covered if they were in the first lien position. However, can we provide the disclosure of the member’s right to receive copies of appraisals and valuations for all our HELOCs?
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