Yes, the new ECOA appraisal requirements apply to commercial loan applicants, provided that the loan will be secured by a first lien on a dwelling. The requirement to provide a copy of all appraisals or written valuations applies to any application for credit to be secured by a first lien on a dwelling, “whether the credit is for a business purpose (for example, a loan to start a business) or a consumer purpose (for example, a loan to purchase a home).” 12 CFR 1002.14(a)Official Interpretations, 12 CFR 1002, Paragraph 14(a), Comment 1. The term “applicant” is defined to include any “natural person, corporation, government or governmental subdivision or agency, trust, estate, partnership, cooperative, or association.” 12 CFR 1002.2(e), (x).
Do the new ECOA appraisal rules apply to business applicants?
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