It looks like you have an exemption from the HPML appraisal requirement at 1026.35(c)(2)(v):
(v) 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.
The exemption is from (c)(3) through (c)(6), which covers all of the HPML appraisal requirements, including the "flip" appraisal.
If your bank does the refi, you'll look at the question of HPML applicability again.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8