Because the rules and objectives are similar, I would like to see the rules for HOEPA and HPML (or HRM as it appears they will now be called) consolidated into one set of rules for higher cost / risk mortgages. The point of both seems to be to protect consumers and ensure they are well informed when entering into a mortgage that is priced higher than most mortgages or that will have higher than usual fees. It's very confusing for lenders to deal with two sets of similar regulations with slight variations.
Comment on CFPB-2012-0031-0018
This is comment on Proposed Rule
Appraisals for Higher-Risk Mortgage Loans
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