An Interagency proposal was released July 10th and seeks to revise (most notably creating additional exemptions) 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.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!