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#2192646 - 09/14/18 05:27 PM Existing Appraisal to New Borrower
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
We have a loan where the borrower died, the person inheriting the property wants to refinance the loan to pay off the existing debt. Can we use the original appraisal since this new request is to a different borrower?

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#2192649 - 09/14/18 05:44 PM Re: Existing Appraisal to New Borrower bgehres
Darth HMDA, CRCM, CAMS Offline
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Darth HMDA, CRCM, CAMS
Joined: Dec 2013
Posts: 1,385
CA
What was the time period between initial loan and now

what does your credit policy state

what does your investor require
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2192651 - 09/14/18 05:49 PM Re: Existing Appraisal to New Borrower bgehres
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
The initial loan was less than a year ago. We would use this appraisal on a new loan to the same borrower. No policy issues and no investor involved.

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#2195698 - 10/17/18 06:57 PM Re: Existing Appraisal to New Borrower bgehres
Know Nothing Offline
New Poster
Joined: Feb 2017
Posts: 2
Another thing to consider would be the HPML rule if this rule applies. If it does and exemptions do not apply then I don't think you have a choice but to have a new outside appraisal.

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#2195790 - 10/18/18 01:08 PM Re: Existing Appraisal to New Borrower bgehres
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
It's a farm and not subject to Reg Z so no HPML issues.

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#2195824 - 10/18/18 03:28 PM Re: Existing Appraisal to New Borrower bgehres
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,995
Toano, VA
Originally Posted By bgehres
It's a farm
That's fine, but is the purpose of the new credit for:

"planting, propagating, nurturing, harvesting, catching, storing, exhibiting, marketing, transporting, processing, or manufacturing of food, beverages (including alcoholic beverages), flowers, trees, livestock, poultry, bees, wildlife, fish, or shellfish by a natural person engaged in farming, fishing, or growing crops, flowers, trees, livestock, poultry, bees, or wildlife"?
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...gone fishing.

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#2196011 - 10/19/18 08:32 PM Re: Existing Appraisal to New Borrower bgehres
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
Both the original and new loans are without a doubt farm purpose and not subject to Reg Z or consumer purpose.

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