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New CFPB Mandated HPML Appraisal Rule for Manufactured Housing effective July 18, 2015

Our focus for today won’t be the wisdom or merits – pro or con – for the new Consumer Financial Protection Bureau (CFPB) imposed Appraisal Rule for manufactured housing that are going to be required on all High Priced Mortgage Loans (HPML). Rather, we will do a review of the information available for those thousands of manufactured housing professionals who have not attended an association meeting or webinar on this subject.

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Thousands of manufactured housing professionals have not yet heard a live presentation on the rules that will go into effect on July 18, 2015.  Please make sure your colleagues have this article with links and read these time sensitive reports.   Image credit Flickr Creative Commons, Luxomart.

 

Let’s note before diving into what follows that we expect a report from DataComp on their approach to this in the next few days. Once that is in hand, we’ll rapidly bring that to your attention.

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Graphic credit – Appraisal New Jersey.

I’d like to quote from John Walter’s thoughtful column describing a philosophy worth considering when new regulations – such as this one – are approached.

“Market forces often push in a direction to keep “business as usual,” despite potential consequences with regulators. Other regulatory concerns, whether real or perceived, may prompt a move too far the other way. Some may even consider exiting from the business altogether. None of those responses speaks to sustainability as a lender or other manufactured housing stakeholders.

Fortunately, these are not the only options from which to choose. 

We can chose to accept and embrace regulation and change to enhance the experience of our business partners and consumers, or as we refer to them in the credit union world, members…we have accepted changes and leveraged…”

Please see his full column linked below, which actually embraces a business approach to regulations that goes beyond the Appraisal Rule.

http://www.MHProNews.com/home/industry-news/industry-in-focus/9904-the-new-appraisal-rule-for-hpml-on-manufactured-homes-finding-the-good-in-regulation-and-change

NADAguides – along with DataComp – have been engaged from the early going in developing tools and resources that can work for manufactured housing retailers, brokers and MH Communities. Here is NADAguides in depth report, which includes a download at the end so you can see their graphics in their full glory.

http://www.MHProNews.com/home/industry-news/industry-in-focus/9907-solution-for-compliance-with-the-new-hpml-appraisal-rule-nadaguides-new-manufactured-home-price-tool

 

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Image credit – idiva.

 

21st Mortgage Corp provided the following linked article, which has been among the read-hot reports in our Featured Articles found on the MHProNews home page.

http://www.MHProNews.com/home/featured-articles/july-2015/137-financing/9809-new-consumer-financial-protection-bureau-appraisal-rule-effective-july-18-2015

Triad Financial Service‘s Don Sharp penned the following column which explains their approach to the QM issue, and how that ties into the Appraisal Rule.

http://www.MHProNews.com/home/featured-articles/july-2015/137-financing/9813-triad-financial-services-position-regarding-7-18-15-implementation-of-new-appraisal-rules

Technically, Cody Pierce’s column is not tied to the new HPML rule. Rather, it highlights a subject that often arises for those doing land/home deals using FHA, VA or USDA lending. Please see Cody’s insightful article, linked below.

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Manufactured Housing Pros can take lemons and make them into lemonade. By leveraging the appraisals, it can be used as a tool to validate the purchase value of the home the shopper wants. Image credit – Birmingham Appraisal Blog.

http://www.MHProNews.com/home/featured-articles/july-2015/137-financing/9815-about-appraisals-on-fha-and-va-land-home-manufactured-housing-loans

Last and absolutely not least, a comprehensive look at QM, the HPML Appraisal Rule and CU Factory Built Lending‘s approach to the issues is linked below.

http://www.MHProNews.com/home/corp-press-releases/9908-cu-factory-built-lending-and-the-new-hpml-appraisal-rule-for-manufactured-housing

We’ll bring you additional information as it becomes available. No one brings you more up-to-date information on the stories that matter to MH Pros than MHProNews. We Provide, You Decide. ©. ##

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L. A. “Tony’ Kovach shown here in an educational session in Louisville, KY.

 

By L. A. ‘Tony’ Kovach.

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