Appraisals for Higher-Priced Mortgage Loans (HPML's)

Mindy Henderson • May 9, 2018

Did you know that in certain circumstances you are required to get TWO full appraisals when creating an owner finance note? TILA Higher-Priced Mortgage Loans (HPML) Appraisal Rule went into affect for applications received on or after January 18, 2014. If you create a loan for a consumer’s primary residence that does NOT meet the Qualified Mortgages standard but meets the definition of a Higher-Price Mortgage Loan, then you must:



  • Disclose to consumers within three days after the consumer applies that they are entitled to a free copy of any appraisal the creditor orders and notify them that they can hire their own appraiser at their own expense.
  • Obtain a written appraisal performed by a certified or licensed appraiser in conformity with USPAP and Title XI of FIRREA
  • The appraiser must do an interior inspection and provide a written report
  • Deliver copies of the appraisals to the applicants no later than three business days before consummation



If the property is a flip (the seller has owned the property less than 180 days), then a second appraisal is required if


  1. The price increase is more than 10% of the purchase price if the seller acquired the property in the past 90 days
  2. The price increase is more than 20% of the purchase price if the seller acquired the property in the past 180 days

The second appraisal must:


  1. Be a written report by a licensed appraiser in compliance with USPAP and FIRREA based on an inter property visit; the appraisal must be done by a different firm than the first appraisal performed
  2. Analyze
    1. Difference in acquisition and sales price
    2. Change in market conditions
    3. Property Improvements the seller made

Remember, by creating a QUALIFIED MORTGAGE, you are exempted from these requirements. Use a qualified RMLO who specializes on working with real estate investors to make sure all of your paperwork is in compliance.

10 Reasons You Should Love Blogging

By Mindy Henderson • May 9, 2018
Anyone can make one: For better or worse, anyone can write a blog post about anything they want. Everyone has a voice and the best voices will rise to the top. The writer can show their personality: In blog posts, the writer has more leeway to add in their voice and personality than other types of writing. Blogs are a great form of mass communication: You can help people, learn new things, entertain your audience-the possibilities are endless and amazing. Blogging opens up all of these to a very wide audience. You can make money: Get the right blog going and you can make a lot of money through advertising and sponsored posts. It allows people to craft better thoughts: Instead of reading haphazard, uneducated Facebook statuses, it's much better to see people's thought process in a well-written blog post. You can establish a community: Blogging allows you to connect with other individuals who share the same interests. Sharing ideas and opinions within your community helps establish yourself as a thought leader. Good for SEO: Keeping content on your site fresh and relevant, you can use your blog to boost the search engine ranking (SEO) of your site and your business. It brings people back to your site: If your blog is strong enough and updated regularly, people will come back looking for more and bring traffic back to your site as well. It's free: It costs you a grand total of zero dollars to post to the blog, so if you have something to say, there's nothing to stop you. You can establish yourself as a thought leader: A blog is a great place for your original thoughts, and it can be a wonderful way to show off your individuality. If people like your ideas, you can become a thought leader in your industry! What else do you love about blogs? Let me know!