I'm trying to find the CFPB list of Rural Counties for 2018. Is it not published yet?

Not yet:

https://www.consumerfinance.gov/policy-c...-counties-list/

Thanks for confirming. Isn't it usually available by now?

Yes usually November

Let's hope this annual emanation from the Bureau isn't delayed by the 30-day suspension of rules and guidance that the new director imposed.

We are a Small Creditor and also Rural and Underserved. I'm finding that we are exempt from the "2nd " appraisal requirements under Reg Z Appraisal Rules for High Priced Mortgage loans over $25,500 (which is going up to $26,000 in January).

But I don't find that we are exempt from "Certified" Appraisals on HPML's over $25,500. In the past we just had an employee with appraisal experience do a one page Evaluation for our "portfolio loans"...that in some cases were HPML's.

If we are Small Creditor/Rural and Underserved aren't we exempt from the Reg Z appraisal rules for HPML's? I just can't find that in writing!

You can't find it because there isn't an exemption.

Parluc, does your bank perhaps require all your portfolio loans to be QMs? If so, they would be exempt due to their QM status...just a thought.

Raitchjay....thank you!!! I was in panic mode! Yes we only do QM's!! I guess I'll go thru the ATR/OM rules to try to find that in writing. I know we visited this a few years ago I am having trouble remembering where to find it.

Thanks for your help everybody!

It's in Sec. 35:

(2) Exemptions. The requirements in paragraphs (c)(3) through (6) of this section do not apply to the following types of transactions:

(i) A qualified mortgage as defined pursuant to 15 U.S.C. 1639c;

Thank You!!

2018 Rural Counties list is posted!

Can you share a link please?

Thanks Bville.

You're welcome. Take note that it goes alphabetically through the states and then starts over again with AK and goes through many of the states again. Seems as though someone didn't do a final sort.

Remind me why we have a "rural underserved" and just a "rural" list?

We use the rural county list to get out of ordering a second appraisal on a HPML flip loan.

Rural and underserved gets you out of other things that I don't remember because my bank doesn't qualify.

Ah ok....thanks. The rural underserved has always been my primary concern.