On July 10, the CFPB, the Federal Reserve Board, Federal Deposit Insurance Corp., Federal Housing Finance Agency, NCUA and the Office of the Comptroller of Currency jointly issued a proposed rule that would create additional exemptions to the TILA (Regulation Z).
The supplemental proposal would provide exemptions to the TILA appraisal requirements for three additional types of HPMLs:
Loans of $25,000 or less;
Certain “streamlined” refinancings; and
Certain loans secured by manufactured housing
Currently, the final rule prohibits a creditor from making a HPML unless, prior to consummation, the consumer obtains a written appraisal performed by a “certified or licensed appraiser” who conducts a physical visit of the interior of the property. The supplemental proposal can be found here.