Would a certified appraisal (written report, physical property visit) be required for a rental property? The rental property meets all definitions of HPML except the "principal dwelling" part.
Posted By: raitchjay
Re: HPML -rental - 03/12/14 04:43 PM
HPML rules in general only apply to principal dwellings, so no, not required under the HPML rules. You'd need to review the Interagency Appraisal Guidelines to see if an appraisal was required for your specific loan amount.
Posted By: rlcarey
Re: HPML -rental - 03/12/14 06:39 PM
required for a rental property
What is the loan purpose? Is this even subject to Regulation Z in the first place?
Good point. Thank you both for your help.
I just wanted to comment here because I had a client tell me they "heard" that rental properties are subject to HPML. I asked where they heard that, and the reply was another bank. I pointed out a loan to aquire, refinance or improve non-owner occupied rental property is specifically excluded from Reg. Z coverage. The only reason such a loan would be subject to Reg. Z was if a consumer pulled equity out of a NOO Rental to use that money for a personal, family or household purpose. That might be where the confusion is coming from.