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I need an opinion on the HPML appraisal rule. The rule states the appraiser physically visit the property and view the interior and produce a written report. To “prove” an interior inspection was done we have requested the appraiser to include photos of the interior in the written report. The rule does not specify that interior photos are to be included in the written report. Our appraiser is a licensed/certified appraiser and follows USPAP. In your opinion is it required per the Regulation for HPML loans to include interior photos of the property?
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Thanks for your question! We brought in a couple of the gurus from BankersOnline:
Barbara Boccia:
While the HPML rule at 12 CFR 1026.35 does not explicitly require interior photos, they are required for loans sold to Fannie Mae and Freddie Mac.
These guides were updated in recent years to require more comprehensive interior photos of living and basement spaces, so the trend is to obtain more, not less, interior photos.
From John Burnett:
I agree with Barbara’s response. Although 1026.35 does not specify that photos be taken of the interior, the Fannie and Freddie sellers guides generally do require them.Interior photos required by Fannie include the kitchen, all bathrooms, the main living areas (living room, family room, dining room/area, all bedrooms, all below-grade finished and unfinished spaces, examples of physical deterioration, if any, and examples of recent updates, such as restoration, remodeling and renovation, if present . [Source, FannieMae Selling Guide, p. 533.]
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