Dodd-Frank Mortgage Reform Act
Answer by Randy Carey, BOL Guru
Question: Relative to the Dodd-Frank Mortgage Reform Act, Sec 1471 Property Appraisal Requirements: the Property Appraisal Requirements have an Interim Final Rule date of Oct 21, 2010. Is this a mandatory compliance date, i.e., for the two appraisal notices: [new] Consumer Notification Sec 129(H)(d) and [revised] Sec 701(e)(5) Right to Copy? I'm getting frustrated. No one can answer this question and I can't figure it out. I can't instruct to have these disclosures in place by Oct 21st if that is not the case. Relative to Second Appraisal Sec 129(H)(b)(2)(A): the lender needs to order two appraisals, correct? One to determine appraised value for the new higher-risk mortgage being processed and a second one to determine why this new sales price is higher than the sales price within the last six months... correct? See Pages 810 and 811 of BOL's online MRAPLA: http://www.bankersonline.com/df_titlexiv.pdf. I have listened to the archive version of BOL's August 31st webinar on "MRAPLA" three times and I can't hear the answer to my questions.
Answer: Section 1400(c) REGULATIONS; EFFECTIVE DATE.—
(1) REGULATIONS.—The regulations required to be prescribed
under this title or the amendments made by this title
(A) be prescribed in final form before the end of the
18-month period beginning on the designated transfer date;
(B) take effect not later than 12 months after the
date of issuance of the regulations in final form.
The transfer date is not until July 2011, so there is plenty of time before you will see the final regulations and then up to a year afterward to comply. It could be as late as Jan. 2014.
First published on BankersOnline.com 11/08/10