Reg B Valuations - What is not considered a valuation?

Compliance > Regulation B - ECOA

Q:  What is not considered a valuation?  (Comment 14(b)(3)-3)

A:  Not all documents that discuss or restate a property’s value are valuations. Documents that discuss property value but are not valuations include:

  • Internal documents that merely restate the estimated value of the dwelling contained in an appraisal or other written valuation you are providing to the applicant (for example, an internal email that only mentions the appraised value in the appraiser’s report to be provided to the applicant)
  • Government agency statements of appraised value that are publicly available
  • Publicly-available lists of valuations (such as published sales prices or mortgage amounts, tax assessments, and retail price ranges)
  • Manufacturers’ invoices for manufactured homes
  • Reports reflecting property inspections that do not provide an estimate or opinion of the value of the property and are not used to develop an estimate or opinion of the value of the property

In addition, an appraisal review that does not itself state a different estimate from the appraisal would not be a valuation you must provide to the applicant.

This can be found in the CFPB's ECOA Valuations Rule, Small Entity Compliance Guide -

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