They are two completely separate rules. One does not affect the other. For example, if your loan isn't an HPML, it won't be subject to the HPML appraisal requirements in 1026.35. But if it's secured by a first lien on a dwelling, the Reg B appraisal rule will apply.
Another example: If the loan is exempt from Reg Z altogether because it's a loan to a corporation or for business purposes, but it's secured by a first lien on a 1-4 family dwelling, it's subject to the Reg B appraisal rule, but, of course, not covered by anything in Reg Z, including the HPML appraisal rule.
There are a lot of other examples, but here's one last one to specifically address your comment, Bibliofiend: If a mortgage loan is a Qualified Mortgage under 1026.43, it qualifies for an exemption from the HPML appraisal rule, but it doesn't give you a "pass" on the Reg B appraisal rule if it's a first lien loan secured by a dwelling.
Last edited by John Burnett; 07/21/15 07:32 PM.
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John S. Burnett
BankersOnline.com
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