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#1904542 - 03/12/14 04:20 PM HPML -rental
morirse de risa Offline
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Midwest
Would a certified appraisal (written report, physical property visit) be required for a rental property? The rental property meets all definitions of HPML except the "principal dwelling" part.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1904563 - 03/12/14 04:43 PM Re: HPML -rental morirse de risa
raitchjay Offline
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OK
HPML rules in general only apply to principal dwellings, so no, not required under the HPML rules. You'd need to review the Interagency Appraisal Guidelines to see if an appraisal was required for your specific loan amount.
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#1904627 - 03/12/14 06:39 PM Re: HPML -rental morirse de risa
rlcarey Online
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rlcarey
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Galveston, TX
required for a rental property

What is the loan purpose? Is this even subject to Regulation Z in the first place?
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#1905219 - 03/13/14 07:40 PM Re: HPML -rental morirse de risa
morirse de risa Offline
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Joined: Feb 2009
Posts: 238
Midwest
Good point. Thank you both for your help.

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#1905574 - 03/14/14 05:50 PM Re: HPML -rental morirse de risa
Princess Romeo Offline

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Where the heart is
I just wanted to comment here because I had a client tell me they "heard" that rental properties are subject to HPML. I asked where they heard that, and the reply was another bank. I pointed out a loan to aquire, refinance or improve non-owner occupied rental property is specifically excluded from Reg. Z coverage. The only reason such a loan would be subject to Reg. Z was if a consumer pulled equity out of a NOO Rental to use that money for a personal, family or household purpose. That might be where the confusion is coming from.
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