3. Who should be considered the loan production staff for purposes of achieving appraiser independence? Could loan production staff select an appraiser?
Answer: The loan production staff consists of those responsible for generating loan volume or approving loans, as well as their subordinates. This would include any employee whose compensation is based on loan volume. Employees responsible for the credit administration function or credit risk management are not considered loan production staff.
Loan production staff should not select appraisers. However, in a small or rural institution or branch, the only individual qualified to analyze the real estate collateral may also be a loan officer, other officer, or director of the institution. To ensure their independence, such lending officials, officers, and directors should abstain from any vote or approval involving loans for which they engaged the appraiser, reviewed the appraisal, or performed an evaluation.
Review can mean a couple of different things. I would hope that any loan officer, underwriter or any person making the credit decision would "review" the appraisal to become familiar with their collateral and its value.
However from the following question in the original post:
. . . can the underwriter making a credit decision be the same one who reviews the appraisal.
That does not appear to be asking the question if it's OK for a review as I just mentioned but rather the compliance review as you mentioned. And IMO they cannot do the compliance review.
The opinions expressed are mine and they are not to be taken as legal advice.