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#1087036 - 11/24/08 07:33 PM Proposed Interagency Appraisal & Eval. Guidelines
Many Hats Offline
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Orlando, FL
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20081113a1.pdf

Has anyone had a chance to review/comment on the proposed changes? If so, I would love to hear everyone's thoughts.

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#1087352 - 11/25/08 02:09 AM Re: Proposed Interagency Appraisal & Eval. Guidelines Many Hats
Ray_ Offline
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Dallas, TX
Does anyone still prepare internal evaluations? If so, what kind of training is being required?

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#1087440 - 11/25/08 01:31 PM Re: Proposed Interagency Appraisal & Eval. Guidelines Ray_
RR Joker Offline
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The Swamp
We do still utilize internal evals. We have a certified appraiser on staff and a jr (I guess would be appropriate) that has received training. Beyond that, I don't know what, if any, CPE requirements they have...

AND, I have not taken the time yet to read the proposal, but I did forward it to Credit Admin.
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#1087496 - 11/25/08 02:38 PM Re: Proposed Interagency Appraisal & Eval. Guidelines RR Joker
Skittles Offline
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TN
I've just skimmed it - I don't believe much is changing - just a lot more emphasis on the current regulation.
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#1087500 - 11/25/08 02:47 PM Proposed Interagency Appraisal & Eval. Guidelines Ray_
elcinoca Offline
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Elizabeth City, NC
Quote:
Does anyone still prepare internal evaluations? If so, what kind of training is being required?


We recently hired an in-house state-certified appraiser to help with evaluations and appraisal reviews.

We too prepare internal evaluations. As for training, we focus on completing our form; when evaluations are permitted and not; emphasize that tax value alone is NOT an evaluation; emphasize independence; etc.

MarkB

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#1087528 - 11/25/08 03:23 PM Re: Proposed Interagency Appraisal & Eval. Guidelines elcinoca
Many Hats Offline
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Orlando, FL
I would also be interested in knowing how you decide when an AVM, an evaluation, and an appraisal will be used. I know it will be different for every bank, but we need to change our thresholds for these and I am trying to gain some insight into how everyone else does it.

For example, do you base it on loan amount alone, or a combination of loan amount and/or other things like loan-to-value, score, property type, etc.?

We have historically based it on loan amount alone (i.e, if loan exceeds $250,000, we order an appraisal). This is not going to cut it right now in this market, so we're brainstorming on what the parameters should be going forward.

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#1088387 - 11/26/08 03:59 PM Re: Proposed Interagency Appraisal & Eval. Guidelines Many Hats
Many Hats Offline
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Orlando, FL
Bump. smile

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#1089307 - 11/28/08 09:40 PM Proposed Interagency Appraisal & Eval. Guidelines Many Hats
elcinoca Offline
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Elizabeth City, NC
I'll chime in. Currently, we do not use AVMs. By themselves, they are not evaluations. Also, in my state, we have to obtain approval from our banking regulator before we can use them.

As for the other issue, we primarily focus on the transaction amount ($250,000 or less; $1,000,000 or less, etc). For riskier properties or purposes (CRE, construction, etc.) we set a lower limit for in-house evaluations. We also differentiate between purchases and refinances. For example, in the last 18 months our policy was amended to require an outside appraisal on ALL purchases, regardless of transaction amount, regardless of whether residential or commercial purpose. We do not use LTV in our decision-making at all since we don't know what the value is until we do an appraisal/evaluation.

MarkB

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