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#2234818 - 04/15/20 01:52 AM HPMLs + COVID Appraisal "Relief"
NoJustNo Offline
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Midwest
If I'm reading this correctly - HPMLs still require an interior appraisal?

Quote
Interior inspections are still required, however, for certain higher-priced mortgage loans.


And also doesn't apply to purchase loans and construction loans?

Quote
The temporary deferrals apply to all residential and commercial real estate secured transactions, including loans for new
money or refinancing transactions, but excluding transactions for acquisition, development, and construction of real estate...

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2234890 - 04/15/20 07:39 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
Dan Persfull Offline
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Dan Persfull
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Posts: 46,126
Bloomington, IN
This is the email I sent out this morning.

The FDIC released a joint Interim Final Rule allowing appraisals to be deferred under certain circumstances up to 120 days after loan closing. If the waiver is utilized we need a tracking mechanism put in place and monitored to insure the appraisal is received within the 120 day period. I would suggest a spreadsheet similar to the one we use for our loan approval exception tracking.

Attached is their summary outlining the deferment in relation to Freddie/Fannie allowances and the Interagency rule. Also attached is the interim final rule.

This deferment does not apply to:

1. Acquisition/purchase transactions
2. Construction loans
3. Development loans
4. If the loan meets the HPML threshold in Reg. Z 1026.35

The deferment applies to both residential and commercial real estate related transactions.

As a reminder:

1. A residential real estate related transactions is one secured by a single 1-4 family residential property with a transaction value =< $400,000.
2. A commercial real estate related transaction is one secured by 2 or more 1-4 family residential properties with a transaction value =< $500,000.

Thanks,
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2235100 - 04/17/20 03:17 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
NoJustNo Offline
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Joined: Oct 2013
Posts: 178
Midwest
Thanks, Dan! Seems like this didn't really provide a ton of relief!

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#2235137 - 04/17/20 06:03 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
Questions Offline
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Posts: 83
So this doesn't apply to purchases? Only refinances?

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#2235179 - 04/17/20 09:53 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,126
Bloomington, IN
The temporary deferrals apply to all residential11 and commercial real estate secured transactions, including loans for new money or refinancing transactions, but excluding transactions for acquisition, development, and construction of real estate, and will be effective upon publication in the Federal Register. The deferred appraisals and the interim final rule will sunset on December 31, 2020.
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#2235296 - 04/20/20 10:11 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
Dave M_TCA Offline
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Dave M_TCA
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Posts: 681
Wherever my most benevolent em...
I don't want to cross post but I saw a similar thread in the Lending Compliance forum and was looking for clarification to a couple statements in the preamble which led me to believe that statement was meant for new development and not purchase loans.

https://www.bankersonline.com/forum...f-appraisals-due-to-covid-19#Post2235088
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All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.

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#2237687 - 06/07/20 08:54 PM Re: HPMLs + COVID Appraisal "Relief" [Re: NoJustNo]
Andy_Z Offline
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Andy_Z
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On the Net
From the perspective that once you fund the loan, it is much harder to get a borrower's cooperation, I can see issues here. I recall my original thought that getting the appraisal after the fact seems a bit meaningless, or could anyway as it might just show you how there wasn't the equity you thought there would be. But I don't know how often that might actually happen. Would a bank ever consider a lower LTV if the appraisal is delayed, and might that have a fair lending impact?
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