This is the first time we will be originating an HMPL loan since the June deadline. We are doing a $12K loan for five years on a primary residence that the borrowers own free and clear. (the only product we really offer for this request is a second mortgage product that comes with a rate of 4.74%)

I am getting confused with what the requirements are today versus what the requirements will be post January 2014.

I know that we are required to have escrow for five years.

Do we have to require a full appraisal? (normally wouldnt on this low a CLTV)

Do we have to require PMI? (we dont usually do PMI on these second mortgage products?)

Any thoughts or clarity would be much appreciated.

You would only need an evaluation.

PMI is not an HPML requirement. It would only be necessary if the LTV exceeds 80% and the bank wanted the protection.

thank you very much Dan.