I have an HPML question I am hoping someone can help me with. Consumer loan secured by a mobile home and land…….HPML, so appraisal has been ordered for this piece of property. In addition, the officer is taking 30 acres of vacant land as an abundance of caution. I know the “abundance of caution” can get you out of the appraisal rules in Part 323, but I can’t find an exemption in Reg Z for appraisals required for HPML’s. I’ve read through the exemptions several times and don’t see one for property taken as an abundance of caution. Am I missing something or does our borrower need to have an appraisal performed on the land as well. FYI….the loan is over $27,200 and is not a bridge or construction loan.

There is no exempt for an abundance of caution under any of the regulations (Reg Z, Flood, etc.), except the appraisal rules.