Small loan requirements

For the HPML appraisal requirements, is there any minimum size loan that will be exempt from the appraisal requirement to be performed by a Licensed/Certifed appraiser?

Example: The custmoer applies for a $10,000 remodeling loan. Now our bank performs an in-house evaluation for this loan. But, with the new Reg Z HPML rules, would we be required to obtain an appraisal from a licensed or certifed appraiser who would do a visit of the inside of the property???

Yes - another side effect of the regulation. It is going to kill small equity loans.

The only exemption I could think of for this would be if it is a QM.

The rule on a second appraisal only applies to certain higher-priced mortgage loans. I did not see such a rule for loans that are not higher priced. The borrower may not be charged for the second appraisal. The holding period is either 90 or 180 days depending on the price of the home.

It appears they are proposing an exemption for HPMLs that are $25,000 or less.

Yes, they are proposing an exemption for HPMLs $25,000 or less. Check this out.

http://www.fdic.gov/news/board/2013/2013-07-09_notice_sum_a_res.pdf?source=govdelivery

I just have to get on my soapbox here for a minute. I spent the last two days writing up training, procedural guidelines, controls, checklists, etc. all about the (first) new appraisal rules and then they issue this?!?!?

I can't keep devoting time to stuff they keep changing - even if the changes are good. They should scrap all of this, go back to Congress and explain they need more time to meet with groups and figure stuff out instead of issuing Final Rules - no wait - we need to amend this --wait! wait! we have a proposal--wait - we are going to add an exemption, etc.

RANT OVER - sorry!

I'm with you TESLA. It's a BIG job to implement all of these in and of themselves AND keep up with the day to day stuff - staff questions, audits, monitoring, managing department staff, keeping the renegade commercial lenders in check, new / changes to products, software, etc.

The merry-go-round just keeps spinning faster and faster each day and time just keeps ticking by. UGH!

thanks for listening, rant over too!

Telsa and Travelgirl I am feeling your pain and frustration also. After yesterday I was ready to pull my hair out. We are running out of time to get all this together and training done. We can't hit everyone with everything at once but we can't continue to prepare training, cheatsheets, etc and then have more changes and have to go back fix everything. This is taking a lot of time and effort and not everyone has unlimited resources

Well, I guess there is comfort in knowing I'm not alone. I am meeting tomorrow to go over the ATR/QM rules and, of course, they changed that too.

Thank God for alcohol!

It has become a ridiculous circus...I've about had it.

Yes I wish DFA would have had an implementation date of Jan 2015. Then all you guys would have to work on it while I am retired and on a beach in the Caribbean soaking up the rays and drinking the Corona.

It is not nice to rub it in!;)