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The HPML appraisal rules have an exemption if the loan is a QM. We are a small creditor so we get a safe harbor for QMs as long as our loan is not more than 3.5 percentage points above the APOR. If we make a loan that is a Safe Harbor QM, we do not have to follow the requirements for HPML appraisals including if it is a flip, correct? Would it be best practice, if we have a loan that is above the actual HPML threshold to still follow the appraisal rules? I guess I am thinking that we may think it is a QM, but if it isn’t for some reason then we will have violated both the Ability to Repay and HPML appraisal rules….especially when Ability to Repay is new…
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