Occ Appraisals And Evaluations Faqs 2018

[Mike Kennedy]

Subject: Appraisals and Evaluations of Real Estate
Date: October 16, 2018

https://www.occ.gov/news-issuances/bulletins/2018/bulletin-2018-39a.pdf

 

[Terrel L. Shields]

Definition of HPML - High price mortgage loan

https://files.consumerfinance.gov/f/201401_cfpb_tila-hpml_appraisal-rule-guide.pdf

 

[Meandering]

Definition of HPML - High price mortgage loan

https://files.consumerfinance.gov/f/201401_cfpb_tila-hpml_appraisal-rule-guide.pdf

When you originate a higher-priced first-lien or subordinate-lien loan covered by the HPML Appraisal Rule,
you must:

Use a licensed or certified appraiser who certifies the appraisal complies with the Uniform Standards
of Professional Appraisal Practice (USPAP) and the Financial Institutions Reform, Recovery and
Enforcement Act (FIRREA) of 1989, as amended, 12 U.S.C. 3331et seq., and any implementing
regulations

Have the appraiser physically visit the property and view the interior and produce a written appraisal
report

Yup,
No hybrid allowed.

 

[Bob Ipock]

When you originate a higher-priced first-lien or subordinate-lien loan covered by the HPML Appraisal Rule,
you must:

Use a licensed or certified appraiser who certifies the appraisal complies with the Uniform Standards
of Professional Appraisal Practice (USPAP) and the Financial Institutions Reform, Recovery and
Enforcement Act (FIRREA) of 1989, as amended, 12 U.S.C. 3331et seq., and any implementing
regulations

Have the appraiser physically visit the property and view the interior and produce a written appraisal
report

Yup,
No hybrid allowed.

When you originate a higher-priced first-lien or subordinate-lien loan covered by the HPML Appraisal Rule,
you must:

 

[Meandering]

III.
What transactions are covered by the ATR/QM rule? (§ 1026.43(a)) The Bureau’s ATR/QM rule applies to almost all closed-end consumer credit transactions secured by a dwelling including any real property attached to the dwelling. This means loans made to consumers and secured by residential structures that contain one to four units, including condominiums and co-ops. Unlike some other mortgage rules, the ATR/QM rule is not limited
to first liens or to loans on primary residences.

However, some specific categories of loans are excluded from the rule.

Specifically, the rule does not apply to:

Open-end credit plans (home equity lines ofcredit, or HELOCs)

Time-share plans

Reverse mortgage

https://files.consumerfinance.gov/f/201310_cfpb_atr-qm-small-entity_compliance-guide.pdf

 

[Meandering]

When you originate a higher-priced first-lien or subordinate-lien loan covered by the HPML Appraisal Rule,
you must:

Still struggling with the concept that interior inspections, performed by appraiser are required for some mortgage products?


Keep trying.

Because you did not say anything new.


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[Bob Ipock]

Still struggling with the concept that interior inspections, performed by appraiser are required for some mortgage products?


Keep trying.

Because you did not say anything new.


.

I fully understand....you don't. Interior inspection appraisals are NOT required for anything under $250,000. You are saying SOME now but you have repeatedly indicated that ALL appraisals must include interior inspection.

 

[Meandering]

Apparently you don't understand.

for Higher priced mortgages that do not qualify for exemptions from appraisals (such as HELOCs), an interior inspection, by the appraiser is required for the mandatory appraisal, for loans over $26,000

Shall I post it again for you to read from the FDIC's website, or are you going to look it back up for yourself?


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[Bob Ipock]

Apparently you don't understand.

for Higher priced mortgages that do not qualify for exemptions from appraisals (such as HELOCs), an interior inspection, by the appraiser is required for the mandatory appraisal, for loans over $26,000

Shall I post it again for you to read from the FDIC's website, or are you going to look it back up for yourself?


.

Does every appraisal call for an interior inspection? NO.

Is there a purpose and a reason for drive-by appraisals? YES

Will the certification and limiting conditions be important to the scope of work required. YES.

 

[Meandering]

Does every appraisal call for an interior inspection? NO.

I never said it did.

It was you making that claim in a previous thread.




https://appraisersforum.com/forums/threads/new-hybrids-coming.221520/page-2

Is there a purpose and a reason for drive-by appraisals? YES

Will the certification and limiting conditions be important to the scope of work required. YES.

Certifications are required by USPAP.

Which still have nothing at all to do with your claims from the previous thread, before the troll was sent in.



https://appraisersforum.com/forums/threads/new-hybrids-coming.221520/page-2

There are loan products that are for less than $250,000 and require interior inspections by the appraiser, by law, and do not qualify for appraisal waivers by the interagencies.

It is the appraiser's responsibility to select the appropriate scope of the work. The appraiser must communicate with the client to know if the loan which is the catalyst for the assignment, requires an interior inspection, or not. It is the appraiser that is responsible for inspecting the comparables from at least the street, and for using GSE forms, if loans are going to be resold to the secondary market.

Jumping on the piped piper bandwagon, telling appraisers they don't have to know anything, just do what they are told, well, that might backfire on you within the next couple of months as the power-grabbers start writing reports about how unreliable appraisers are, and how those reports don't meet the requirements of the GSEs, or of the TILA. Just because FHA was the first to start, it doesn't make them the last. It's the building storm clouds, and you may chose to help build those big storm clouds, but I never did.


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