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#1654358 - 01/23/12 05:19 PM Higher Priced Mortgage Appraisal Rules
Sugarbaker Offline
Gold Star
Joined: Nov 2005
Posts: 265
Have the Higher Risk Mortgage rules under section 1400 of Dodd Frank become effective (specifically the appraisal requirements for Higher Risk Mortgages)? I'm hoping I haven't missed it - I don't recall seeing anything finalized.

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Lending Compliance
#1654666 - 01/23/12 09:44 PM Re: Higher Priced Mortgage Appraisal Rules Sugarbaker
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
I asked the same question of the ABA back in August. This was the reply I got:

"These requirements will be established by a rulemaking jointly with the CFPB and the FRB which the statute requires within 18 months of the transfer date, which was July 21, 2011. The rule should be out sooner, but our reading is that implementation must await the final rule, even if the agencies miss the 18 month deadline. Based on current activity at CFPB, we assume that the ability to pay/QM rulemaking, RESPA/TILA re reform, and consumer compliance supervision for banks over $10 billion in size will take precedence over section 1471. But, we are asking CFPB to publish a likely schedule so we can get a better idea when various parts of Dodd-Frank are likely to come on line, and banks can better plan and manage compliance efforts."

Hope that helps!

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