Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network



January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



Topic Options
#1857407 - 10/01/13 02:56 PM What happens with subordinate liens after 1/18?
BNach Offline
Junior Member

Registered: 07/15/11
Posts: 39
Loc: Central PA
Here is another Reg B appraisal question that has me stumped. Currently, Reg B applies to all loans secured by a dwelling. As you know, we have to give the Right to Receive notice to all loans secured by a dwelling. The new rule only covers 1st liens on a dwelling. So, after January 18th we will have to provide notice and appraisals to all applicants who apply for a loan secured by a 1st lien on a dwelling. So, what happens to the subordinate liens after January 18th? We have no Reg B appraisal requirements for subordinate liens? I would tend to believe that that is the correct answer since the regulation is silent on it but it seems like they would mention it since we currently have a responsibility to give them a notice.

Top
Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1857441 - 10/01/13 03:43 PM Re: What happens with subordinate liens after 1/18? [Re: BNach]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 16497
Loc: The Swamp
The changed language doesn't include any requirements for subordinates, so my take is...it disappears when the new rule takes over.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Top
#1857834 - 10/02/13 04:00 PM Re: What happens with subordinate liens after 1/18? [Re: BNach]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30979
Loc: Cape Cod
1) You still have to conform to the Interagency Appraisal Guidelines.

2) There will not be a Regulation B requirement after 1/18/14 for notices or appraisal copies for junior-lien secured loans.

3) However, there remains the matter of the HPML appraisal requirement under Reg Z 1026.35(c). If the loan in question is closed-end and secured by the consumer's principal dwelling, and otherwise fits the definition of an HPML at 1026.35(a)(1) for a junior lien-secured loan, the appraisal requirements of section .35(c) will apply.
_________________________
John S Burnett
BankersOnline.com

Top
#1883698 - 01/07/14 10:17 AM Re: What happens with subordinate liens after 1/18? [Re: John Burnett]
DCollins Offline
Platinum Poster

Registered: 10/26/01
Posts: 704
If we decide to give our customers their appraisal even if the loan is a junior lien, are we in violation to the new requirements?

Top
#1883702 - 01/07/14 10:21 AM Re: What happens with subordinate liens after 1/18? [Re: BNach]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 16497
Loc: The Swamp
No.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Top