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



June 11, 2015
New Tech Advances to Improve Info Security
Susan Orr

June 22, 2015
50 Key Considerations for Integrated Disclosure Rules Readiness
Mary Beth Guard and Jack Holzkechnt

June 23, 2015
The IRS and TINs: The High Cost of Name Mismatches
Deborah Crawford

July 15, 2015
All About Escrows
David Dickinson



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: 41
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: 16858
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: 31984
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: 16858
Loc: The Swamp
No.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Top