On the safe harbor - if the bank sells to both Fannie and Freddie - then would the lender need to present both a Fannie and Freddie that the applicant expressed an interest in and would likely qualify for?

On the appraisal independence - we are less than $250 mil. If we use a rotating list and Loan Operations orders, will that work? Can the appraisal or valuation review be done by a qualified Loan Operations staff since that person doesn't vote on the loan?