Appraisal requirements and HPMLs

Our bank will originate small second mortgages loan which will be HPMLs. We have under $2 billion in assets and originate only a few first mortgages.

1) Does this mean that we will not be required to order appraisals?
2) If the DTI exceeds 43% (we will go up to 45%), would we then be required to order appraisals? (None will be sold and we verify all income).

Thanks all!

How small? Less than $27,200? Will they be QMs?

Our second mortgages will range from $10K to $75K but they would be QMs.
So, would them being QMs mean no appraisal is required (even if over $27,200$)?

1026.35(c)(2) Exemptions. The requirements in paragraphs (c)(3) through (6) of this section do not apply to the following types of transactions:

(i) A qualified mortgage as defined pursuant to 15 U.S.C. 1639c;