I am hoping you can provide me with some confirmation on a particular point with respect to the ECOA valuations rule that went into effect on 1/18/14. If we have a commercial construction builder with a first-lien construction loan on a dwelling, do we have three (3) business days to notify the applicant of the right to receive a copy of appraisals, enable them to waive the right to receive them 3 days prior to close and give them the appraisal at or prior to consummation or account opening? I am receiving push back on whether this applies to a commercial construction loan. Any assistance you can give would be greatly appreciated. Thanks in advance.
You are correct, Regulation B coverage is not limited to consumer credit so if a commercial loan is secured by a first lien on a dwelling the valuation rules will apply.
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