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).