HPML Appraisal Policy
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Since its effective date on January 10, 2014, no single regulation has caused more general confusion and duplication of overlaying regulation than the Higher Priced Mortgage Loan Appraisal Rule. For one, if you only originate QM loans, you don't have to worry about the HPML rules.
It also seems that, if we are making loans for re-sale into the secondary market, and we are complying with the ECOA appraisal rules, we already execute the required functions of the rule as a safeguard for sudden non-QM compliance. Companies that have adopted the best practices of secondary marketing do comply. But there are several wrinkles. Our policy ensures that you have controlled your process to catch these requirements as part of your procedure. It includes: The "Flip" rule Interior Inspections Requirements of the Appraisal Report Owners of the Mortgage Compliance Policies and Procedures, or any of the complete packages for Small Broker, Correspondent, or Banker/Credit Union/Lender already own this product and can obtain updates. |
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