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#2242389 - 09/14/20 04:48 PM Appraisal requirements and HPMLs
JoeG Offline
Member
Joined: Nov 2013
Posts: 89
DuPage county, IL
Our bank will originate small second mortgages loan which will be HPMLs. We have under $2 billion in assets and originate only a few first mortgages.

1) Does this mean that we will not be required to order appraisals?
2) If the DTI exceeds 43% (we will go up to 45%), would we then be required to order appraisals? (None will be sold and we verify all income).

Thanks all!

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2242398 - 09/14/20 05:41 PM Re: Appraisal requirements and HPMLs [Re: JoeG]
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 74,449
Galveston, TX
How small? Less than $27,200? Will they be QMs?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2242404 - 09/14/20 06:09 PM Re: Appraisal requirements and HPMLs [Re: rlcarey]
JoeG Offline
Member
Joined: Nov 2013
Posts: 89
DuPage county, IL
Our second mortgages will range from $10K to $75K but they would be QMs.
So, would them being QMs mean no appraisal is required (even if over $27,200$)?

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#2242408 - 09/14/20 07:08 PM Re: Appraisal requirements and HPMLs [Re: JoeG]
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 74,449
Galveston, TX
1026.35(c)(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;
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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