.... we are 'over-interpretting' the recent appraisal and evaluation guidelines.
That's what's driving it here. We currently do full blown on all real estate loans, due to the Reg Z appraisal rules and HVCC.
I think since these loans are not sold on the market, that discounts HVCC rules, and we wouldn't need to do Full Blown Appraisals.
These loans avereage in size of about $46k with the rare loan amoutn over $100k. So, I don't see a need for a full blown appraisal.