Skip to content
BOL Conferences
Thread Options
#1904542 - 03/12/14 04:20 PM HPML -rental
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
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.

Return to Top
Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1904563 - 03/12/14 04:43 PM Re: HPML -rental morirse de risa
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
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.
_________________________
I'm fixin' to fix that.

Return to Top
#1904627 - 03/12/14 06:39 PM Re: HPML -rental morirse de risa
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
required for a rental property

What is the loan purpose? Is this even subject to Regulation Z in the first place?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1905219 - 03/13/14 07:40 PM Re: HPML -rental morirse de risa
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
Good point. Thank you both for your help.

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

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
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.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top