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#1957653 - 08/28/14 01:14 PM HPML Appraisal Requirement
ComplianceNewby Offline
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ComplianceNewby
Joined: Feb 2014
Posts: 110
Louisiana
If we are doing a true bridge loan where there will be no permanant financing and the loan is for 9 months, is an outside appraisal required?
Last edited by John Burnett; 08/28/14 01:46 PM.
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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1957662 - 08/28/14 01:39 PM Re: HPML Appraisal Requirement ComplianceNewby
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Using the subject line of your post as an indicator of which rule you're concerned about, if the loan meets the HPML definition, the HPML appraisal rule would apply unless the loan fits one of the several exemptions from that rule. One of the exemptions reads: "A loan with maturity of 12 months or less, if the purpose of the loan is a 'bridge' loan connected with the acquisition of a dwelling intended to become the consumer's principal dwelling."

If your loan fits that exemption (or any of the other exemptions under 1026.35(c)(2)), the HPML appraisal rule won't apply. Whether an outside appraisal would be required under other requirements will depend upon the circumstances of the transaction and your bank's loan policy.
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John S. Burnett
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#1957664 - 08/28/14 01:42 PM Re: HPML Appraisal Requirement ComplianceNewby
ComplianceNewby Offline
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ComplianceNewby
Joined: Feb 2014
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Louisiana
What other rules should I be concerned with?

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#1957671 - 08/28/14 01:54 PM Re: HPML Appraisal Requirement ComplianceNewby
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Take a look at the FDIC's Appraisals regulation at 12 CFR Part 323. Also check Louisiana law to determine whether it includes any appraisal requirements on the transaction you're reviewing.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1957687 - 08/28/14 02:12 PM Re: HPML Appraisal Requirement ComplianceNewby
ComplianceNewby Offline
100 Club
ComplianceNewby
Joined: Feb 2014
Posts: 110
Louisiana
Ok, Thank you!!

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