A borrower obtains a subordinate lien HPML on a property where the first lien was originated 18 months ago by the same creditor. The combined loan-to-value ratio is 95%. What appraisal requirement applies?
Correct Answer
B) One full appraisal plus one additional valuation method
Under TILA Section 1026.35(c), HPMLs with LTV ratios above 90% require one full appraisal plus one additional valuation method. This applies to subordinate lien HPMLs when the combined LTV exceeds 90%, even if the same creditor holds the first lien.
Why This Is the Correct Answer
Under TILA Section 1026.35(c), HPMLs with LTV ratios above 90% require one full appraisal plus one additional valuation method. This applies to subordinate lien HPMLs when the combined LTV exceeds 90%, even if the same creditor holds the first lien.
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