The #3 question in the interagency guidelines is: Who should be considered the loan production staff for achieving appraiser independence. Could loan production staff select an appraiser.

The answer is: The loan production staff consists of those responsbile for generating loan volume or approving loans. "This would include any employee whose compensation is based on loan volume. Employees responsible for credit administration function or credit risk management are not considered loan production staff"

So we have loan clerks, who occassionally take applications and order the appraisal for that loan. We have loan officers (whose income is not commissioned)who take applications and advise their subordinates who to order appraisals (the same loan clerks)from. I might add the LO may also be one of the two people needed to approve the loan.

The LO reads this question as "independence" in ordering the appraisal does not apply to any of his people because clerks/LOs are not commissioned-they get the same amount of pay regardless. He's reading this answer as it only applies to "commissioned" LOs.

I'm reading this question as it does apply to loan clerks, LOs, and oh by the way it also includes (but not limited to)commissioned LOs and have suggested they institute a revolving list they select from. Of course they all want to continue to use the appraisers they are comfortable with.

Any thoughts?

Thanks

What about the following does your loan officer not understand?

The loan production staff consists of those responsible for generating loan volume or approving loans. "This would include

Thank you. I'm trying to protect the bank, the LO is trying to make it easier for his staff and of course I am always in the way of that-trying to tell him he's probably got to do more than he is . . .the nerve of me. I just wanted to make sure I wasn't "reading too much into it . . . again" (his quote-not mine) Thanks again Dan.

You also might want to let him know about the proposed changes/emphasis on the FIRREA appraisal regulation. They want a 'robust' program - their word - not mine.

Perhaps he isn't reading enough into it.

Loan Officers are cheap enough. If this one is broke, buy a replacement.

MJ-Oh if only I could . . . all I want for Christmas is a new loan officer. Funny-thanks I needed that.