Comment on CFPB-2012-0031-0018

The requirement to obtain, at the bank's cost, a second appraisal when the seller is selling the home within 180 days of acquisition will limit credit to consumers. Typically banks are able to make home loans to borrowers that might not otherwise be able to obtain the credit via more traditional means that can be sold on the secondary market. That flexibility could make the loan not meet the definition of a qualified mortgage. If that is the case the cost of an additional appraisal would make booking the loan unprofitable and therefore limit credit to consumers.