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Assuming loan in question is an HPML
1. Exemption on appraisal rules refers to Qualified Mortgage. Does this include Small Creditor Qualified Mortgage?
2. Does the exemption cover the rules for having to have an internal inspection, 2nd appraisal, and the copy 3 days before closing?
1) Yes, the HPML appraisal QM exemption includes small creditor portfolio QMs under 1026.43(e)(5) as well as any other qualified mortgages under § 1026.43(e) as well as
§ 1026.43(f).2) The requirements in paragraphs 1026.35(c)(3) through (6) (which includes all the requirements you mentioned) do not apply to a loan that meets the HPML appraisal exemption criteria. Keep in mind the Reg B appraisal/valuation delivery requirements may still apply.
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