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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Interagency (Reg Z) and CFPB Reg B Appraisal Rules HPML Appraisal Exemption
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#2158897 - 01/02/18 06:07 PM HPML Appraisal Exemption
lisawin Offline
Member
Joined: Sep 2015
Posts: 77
Mississippi
We are a CDFI bank and a small creditor. My question is would we be exempt from the HPML appraisal rule?

Thanks

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2158902 - 01/02/18 06:51 PM Re: HPML Appraisal Exemption lisawin
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Not because of either of those two factors.
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#2158920 - 01/02/18 07:47 PM Re: HPML Appraisal Exemption lisawin
lisawin Offline
Member
Joined: Sep 2015
Posts: 77
Mississippi
Just to make sure I understand if we are a small creditor that lends predominantly in rural and underserved areas would that exempt us?

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#2158930 - 01/02/18 08:26 PM Re: HPML Appraisal Exemption lisawin
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Go here: https://www.bankersonline.com/regulations/12-1026-035#c2

It lists all of the exemptions for HPML appraisals.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2159487 - 01/05/18 10:14 PM Re: HPML Appraisal Exemption lisawin
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
They are very different from the exemptions from the escrow requirement.
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