Under ECOA, is an appraisal report required for an RV? The regulation defines a dwelling as a mobile or manufactured home, but it's not really clear whether that includes an RV, whether it's affixed to land or not. How do I know whether a lien on an RV would warrant the providing of an appraisal report?
Reg B, which implements the Equal Credit Opportunity Act, doesn't require that there be an appraisal, but that if there is one on a dwelling, then it must be made available to the applicant. You are correct in that an RV is not defined as a dwelling, one way or the other, but the bottom line would be if a lender wants an appraisal of some sort they will have to have it. An RV may be in a Kelly Blue Book or NADA valuation guide, but because of the variety of options available a more precise valuation may be necessary from a knowledgeable expert. As a lender, we'd offer a copy of that to the applicant to verify that what was listed as options and conditions was true and correct.
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