When we are using an appraisal vendor whose responsibilities are to manage our appraisal process and select approved appraisers, engage them, review the appraisals, etc. can we rely on a third party for review of the company as per the new Appraisal Guidelines?

The Guidance sure doesn't discuss using a third party to do your due diligence for you. I would think if you could prove/document why using that third party to "vet" your appraisal mangement company would benefit your insititution much better than if it was done in-house I could see going that route. It's just common sense, as long as you can document, document, document enough to convince your regulator why going that route enlists expertise not available in your institution.

Full disclosure - I'm in to the "common sense" approach with this guidance. This is based on the many conversations and interactions I have had with our OCC examiners over the last few years. Others might look to the absolute letter of the guidance not addressing this specific area and disagree with me.

We are a small bank and don't have anyone qualified and trained in the real estate area on appraisals to do the review and audit except the loan officer and she can't do them. So what are others doing in that situation?

We use a lender that was in no way part of that loan (as officer, approving party...), send it out for independent third party review (for larger credits) or use one of our analysts that is qualified to review.