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#1871007 - 11/14/13 02:55 PM Reg Z Exemption from new appraisal requirement
dlcooper Offline
New Poster
Joined: Aug 2011
Posts: 10
This may be one of those dumb questions but for clarification purposes here goes... We are not a small creditor and if we have an HPML loan that we have determine is a flip loan but it is located in a rural county as designated on the CFPB's list - this would make the loan exempt from requiring the second appraisal?
We were under the impression that the rural county list was for small creditors use only.
Thanks.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1871015 - 11/14/13 03:07 PM Re: Reg Z Exemption from new appraisal requirement dlcooper
ComplianceNerd Offline
Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
Properties located in rural/underserved counties as defined in 1026.35(b)(2)(iv)(A) are exempt.

1026.35(b)(2)(iv)(A) A county is "rural" during a calendar year if it is neither in a metropolitan statistical area nor in a micropolitan statistical area that is adjacent to a metropolitan statistical area, as those terms are defined by the U.S. Office of Management and Budget and as they are applied under currently applicable Urban Influence Codes (UICs), established by the United States Department of Agriculture's Economic Research Service (USDA-ERS). A creditor may rely as a safe harbor on the list of counties published by the Bureau to determine whether a county qualifies as "rural" for a particular calendar year.

it doesn't mention that you have to be a small creditor.
_________________________
Can't is not an option.

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