Yes, we believe that the ECOA appraisal requirements do apply to this loan. The ECOA appraisal requirements apply to any loan “secured by a first lien on a dwelling,” and there is no exception for construction or temporary loans.

For resources related to our guidance, please see:

• Regulation B, 12 CFR 1002.14(a) (“A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling. A creditor shall provide a copy of each such appraisal or other written valuation promptly upon completion, or three business days prior to consummation of the transaction (for closed-end credit) or account opening (for open-end credit), whichever is earlier. . . .”)