Valuations - What does not count as a valuation?

Compliance > Regulation B - ECOA

Q:  What does not count as a valuation?

A:  As clarified by the Reg. B Official Interpretations to 12 CFR 1002.14, not all documents that discuss or restate a valuation of an applicant's property constitute a “valuation” for purposes of § 1002.14(b)(3). Examples of documents that discuss the valuation of the applicant's property or may reflect its value but nonetheless are not “valuations” include but are not limited to:

i. Internal documents that merely restate the estimated value of the dwelling contained in an appraisal or written valuation being provided to the applicant.

ii. Governmental agency statements of appraised value that are publically available.

iii. Publicly-available lists of valuations (such as published sales prices or mortgage amounts, tax assessments, and retail price ranges).

iv. Manufacturers' invoices for manufactured homes.

v. Reports reflecting property inspections that do not provide an estimate of the value of the property and are not used to develop an estimate of the value of the property.

vi. Appraisal reviews that do not include the appraiser's estimate of the property's value or opinion of value.

Information to support this Q&A can be found in Regulation B, which may be found here:

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