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#1146910 - 03/18/09 03:09 PM
Ordering Appraisals - New requirement May 1st?
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Member
Joined: Jun 2005
Posts: 88
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Hello,
Some of our loan officers just left a meeting with our rep for secondary market loans.
The rep told our group that effective May 1st of this year the recommendation that appraisals be ordered from an independant source (not the loan officer) was no longer a recommendation but MANDATORY by Federal Reg. Did I miss something?
Thanks
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#1147052 - 03/18/09 04:31 PM
Re: Ordering Appraisals - New requirement May 1st?
Gertie
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Diamond Poster
Joined: May 2005
Posts: 1,813
Giant side of TX
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In Nov The FFIEC Regulators released for comment new Appsl Guidelines, basically to bring them up to 2006 USPAP changes and to beef up the required review process. What you are likely talking about is the Home Valuation Code of Conduct that was released in Jan & applies to banks that sell loans to Fannie or Freddie. But before you say "My bank doesn't sell to them so this doesn't apply to us". . . The secondary market purchaser you sell to - does sell to FNMA & Freddie so it is basically trickle down. Your purchasers are saying we have to follow this new HVCC and therefore if you want to sell to us you have to follow it too. See This prior thread
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My opinions are just that, and might be worth what you paid for them.
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#1149453 - 03/23/09 01:10 AM
Re: Ordering Appraisals - New requirement May 1st?
ktac MITCH
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Gold Star
Joined: Jun 2002
Posts: 310
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Our institution is also under $250,000,000 but we do sell to investors that sell to Fannie. What are other institutions doing about the requirement that anyone in the loan production area cannot order the appraisal? Can the appraisals be ordered randomly off of a list? Can loan processors pick the appraiser? We don't have anyone qualified outside of the secondary market loan production area that would be qualified in selecting appraisers. Thanks for any help.
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#1149461 - 03/23/09 03:14 AM
Re: Ordering Appraisals - New requirement May 1st?
tjbanker
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Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
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We are also a bank under $250 million. We have changed our procedures so that the "back office" Credit Administration staff order all appraisals.
We rotate our appraisers randomly from our board approved list. We do, however, consider each appraiser's market area when selecting.
We do not allow the loan processors to choose. Anyone that directly makes (approves) loans and the people that work for them are not involved in the process.
What qualifications would they need to order an appraisal? As long as you have a board approved list and they have a general understanding of the appraisers market area, I don't see the problem. Now, reviewing appraisals is another issue.
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#1169986 - 04/24/09 06:02 PM
Re: Ordering Appraisals - New requirement May 1st?
Ray_
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Power Poster
Joined: Nov 2003
Posts: 3,738
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What are the requirements for someone to review the appraisal? For instance, where do you find training for this individual?
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#1170027 - 04/24/09 06:41 PM
Re: Ordering Appraisals - New requirement May 1st?
Ray_
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Appraisal reviews for small banks will be a challenge. If attempted in-house the person or dept. will need to be independent of the lending function and have the required skills to review the bank's appraisals. The HVCC has complicated the process enough now the state's are getting in on the act with new laws regarding Appraisal Management Companies. Has anyone considered using a third-party source for ordering and reviews?
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#1170039 - 04/24/09 06:49 PM
Re: Ordering Appraisals - New requirement May 1st?
ccman
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Power Poster
Joined: Nov 2003
Posts: 3,738
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We are a small bank and we do, what I call, a compliance review of the appraisal. Is it signed, is the appraiser's license current, is it the right house, was it ordered by the lender?, etc. It does not get into is the value appropriate, etc. SO FAR - this has been ok, but to comply with HVCC I am trying to get a dedicated person for ordering and reviewing appraisals. This person is currently a teller. I want to get her trained, but I am not sure if the compliance review we do is enough or if I need to send her to an appraisal school (class) on appraisal review. What is required?
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#1179212 - 05/08/09 03:52 PM
Re: Ordering Appraisals - New requirement May 1st?
Tesla
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100 Club
Joined: Mar 2006
Posts: 195
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What qualifications would they need to order an appraisal? As long as you have a board approved list and they have a general understanding of the appraisers market area, I don't see the problem. Now, reviewing appraisals is another issue.
Has anyone figured out the answer to the above question yet?
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#1180608 - 05/11/09 07:13 PM
Re: Ordering Appraisals - New requirement May 1st?
Truffle Royale
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100 Club
Joined: Oct 2007
Posts: 151
Va Beach, VA
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We have a "set-up" person who does compliance on all incoming loans and he is the one that orders all appraisals, off of a rotating list. And like Truffle says our underwriter still reviews the appraisal.
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"I used to have a handle on life, but it broke!"
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#1180610 - 05/11/09 07:15 PM
Re: Ordering Appraisals - New requirement May 1st?
TattChica
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Diamond Poster
Joined: Jan 2004
Posts: 1,621
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a couple of people put in their posts "under 250,000,000" - is there an exclusion for under 250 million in assets?
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My views, not my employer's views.
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#1182859 - 05/13/09 08:39 PM
Re: Ordering Appraisals - New requirement May 1st?
Queen Mum
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10K Club
Joined: Jul 2003
Posts: 17,410
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too funny. I just did while you were posting this. Great royal minds....
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#1182925 - 05/13/09 09:42 PM
Re: Ordering Appraisals - New requirement May 1st?
Truffle Royale
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Diamond Poster
Joined: Dec 2003
Posts: 1,363
Wisconsin
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Is this a form provided by the secondary market? I don't think that we're using it and I can't find it on Freddie Mac anywhere.
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#1183063 - 05/14/09 12:50 PM
Re: Ordering Appraisals - New requirement May 1st?
Truffle Royale
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Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
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Do we need o use this form on in-house loans?
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