Another Day…Another Proposal

An Interagency proposal was released July 10th and seeks to revise (most notably creating additional BSA Training and Banking Regulations Compliance Consulting diane11 - Another Day...Another Proposalexemptions) the HPML appraisal requirements scheduled to take effect in January.

The following additional HPML transactions would be exempt from the appraisal requirements under this proposal:

  • Transactions secured by an existing manufactured home but not land.
  • Certain refinance transactions where no additional funds (beyond the cost of the refinance) are extended and that don’t include risky features, such as a balloon payment or negative amortization.
  • Loans that do not exceed a specified dollar amount; which will be adjusted annually.  The proposed threshold is  $25,000 for 2014.

Although it is becoming more difficult to keep all of this straight, the good news is there does not appear to be any additional requirements and it should actually relax some of the requirements that exist under today’s Final Rule.

Published
2013/07/12
Diane Dean

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