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#1815084 - 05/16/13 07:37 PM Small loan requirements
Kim M. Offline
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Joined: Oct 2005
Posts: 129
Kansas
For the HPML appraisal requirements, is there any minimum size loan that will be exempt from the appraisal requirement to be performed by a Licensed/Certifed appraiser?

Example: The custmoer applies for a $10,000 remodeling loan. Now our bank performs an in-house evaluation for this loan. But, with the new Reg Z HPML rules, would we be required to obtain an appraisal from a licensed or certifed appraiser who would do a visit of the inside of the property???

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1815102 - 05/16/13 07:50 PM Re: Small loan requirements Kim M.
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,310
Galveston, TX
Yes - another side effect of the regulation. It is going to kill small equity loans.
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#1815165 - 05/16/13 09:07 PM Re: Small loan requirements Kim M.
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
The only exemption I could think of for this would be if it is a QM.
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#1831309 - 07/09/13 05:49 PM Second Appraisals Kim M.
dog1 Offline
Member
Joined: Apr 2013
Posts: 54
Bucks Cnty, PA
The rule on a second appraisal only applies to certain higher-priced mortgage loans. I did not see such a rule for loans that are not higher priced. The borrower may not be charged for the second appraisal. The holding period is either 90 or 180 days depending on the price of the home.

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#1831811 - 07/10/13 07:13 PM Re: Second Appraisals Kim M.
Tesla Offline
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Joined: Nov 2003
Posts: 3,681
It appears they are proposing an exemption for HPMLs that are $25,000 or less.
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#1831817 - 07/10/13 07:26 PM Re: Second Appraisals Kim M.
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,172
Yes, they are proposing an exemption for HPMLs $25,000 or less. Check this out.

http://www.fdic.gov/news/board/2013/2013-07-09_notice_sum_a_res.pdf?source=govdelivery

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#1831836 - 07/10/13 08:11 PM Re: Second Appraisals Kim M.
Tesla Offline
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Joined: Nov 2003
Posts: 3,681
I just have to get on my soapbox here for a minute. I spent the last two days writing up training, procedural guidelines, controls, checklists, etc. all about the (first) new appraisal rules and then they issue this?!?!?

I can't keep devoting time to stuff they keep changing - even if the changes are good. They should scrap all of this, go back to Congress and explain they need more time to meet with groups and figure stuff out instead of issuing Final Rules - no wait - we need to amend this --wait! wait! we have a proposal--wait - we are going to add an exemption, etc.

RANT OVER - sorry!
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#1831922 - 07/10/13 10:20 PM Re: Second Appraisals Tesla
travelgirl Offline
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Joined: Mar 2004
Posts: 223
Minnesota
I'm with you TESLA. It's a BIG job to implement all of these in and of themselves AND keep up with the day to day stuff - staff questions, audits, monitoring, managing department staff, keeping the renegade commercial lenders in check, new / changes to products, software, etc.

The merry-go-round just keeps spinning faster and faster each day and time just keeps ticking by. UGH!

thanks for listening, rant over too!

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#1831950 - 07/11/13 01:30 PM Re: Second Appraisals Kim M.
JobSecurity Offline
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Joined: Oct 2009
Posts: 579
Telsa and Travelgirl I am feeling your pain and frustration also. After yesterday I was ready to pull my hair out. We are running out of time to get all this together and training done. We can't hit everyone with everything at once but we can't continue to prepare training, cheatsheets, etc and then have more changes and have to go back fix everything. This is taking a lot of time and effort and not everyone has unlimited resources frown
Last edited by JobSecurity; 07/11/13 01:30 PM.
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#1832197 - 07/11/13 06:30 PM Re: Second Appraisals JobSecurity
Tesla Offline
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Joined: Nov 2003
Posts: 3,681
Well, I guess there is comfort in knowing I'm not alone. I am meeting tomorrow to go over the ATR/QM rules and, of course, they changed that too.

Thank God for alcohol!
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#1832382 - 07/12/13 01:56 PM Re: Second Appraisals Kim M.
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
It has become a ridiculous circus...I've about had it.
Last edited by RR Joker; 07/12/13 02:30 PM. Reason: major typo!
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#1832421 - 07/12/13 02:36 PM Re: Second Appraisals Kim M.
zitch70 Offline
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Joined: Apr 2001
Posts: 331
Edinburg, Texas
Yes I wish DFA would have had an implementation date of Jan 2015. Then all you guys would have to work on it while I am retired and on a beach in the Caribbean soaking up the rays and drinking the Corona.

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#1832939 - 07/15/13 05:38 PM Re: Second Appraisals zitch70
Tesla Offline
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Joined: Nov 2003
Posts: 3,681
Originally Posted By: zitch70
Yes I wish DFA would have had an implementation date of Jan 2015. Then all you guys would have to work on it while I am retired and on a beach in the Caribbean soaking up the rays and drinking the Corona.


It is not nice to rub it in!;)
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