I would like to comment concerning the proposal for a second appraisal if the seller has purchased the property within six months of selling it and at a higher price. Most of the situations where we would see this would be a person buys the house and remodels it and sells to to a consumer who applies for a loan with us. It's very easy to see why the seller is selling the property for more money. I don't see how getting a second appraisal is going to help the consumer. This is just going to add additional time and cost to the process. I know the proposal states the buyer can't be charged for the appraisal but this usually translates into them paying in other areas. This happens by other fees being raised to make up for the expense of paying for extra appraisals or the seller paying it which translates to the price on the house being raised.
Comment on CFPB-2012-0031-0018
This is comment on Proposed Rule
Appraisals for Higher-Risk Mortgage Loans
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