We have read in several different places that if a loan is a QM , as defined in regulation z 1026.43(e) it is exempt from the HPML appraisal rules. We are taking this as if we have a Small creditor Qualified Mortgage that is a HPML is it exempt from the HPML Appraisal rules including if they sell the home within 90 days at an increases of 10 % or 91-180 days at 20 % over the price they bought the home at. Is this correct?
I agree with your interpretation. If you have a QM then you are exempt from the HPML appraisal requirements including the additional requirements for a flip.