My bank occasionally takes a first lien in a one to four-unit residence for commercial loans as an abundance of caution, and often the bank does not order an appraisal on those residential properties. Is the bank required to provide a copy of the appraisal notice required by §1002.14(a) of Regulation B (Equal Credit Opportunity Act), even if an appraisal will not be ordered and the property is securing the loan only as an abundance of caution?

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