In light of the newest Interagency Guidelines for appraisals, how long do you consider an appraisal or evaluation good for? I thought the guidelines stated you can reuse an appraisal or evaluation but must "validate" it, which is like conducting an evaluation again to confirm it is still accurate.

Currently we always get something, a new appraisal or conduct an independent in-house evaluation.

This has been a burden, as some of our customers will use the same collateral for multiple loans that may be originated only a few months apart.

Is anyone using a risk based approach and deeming appraisals or evaluations as "good" for a certain period of time before requiring a new one or going through a validation process? For instance, all appraisals or evaluations that are less than 3 months are acceptable for re-use automatically...

all appraisals or evaluations that are less than 3 months are acceptable for re-use automatically

The Interagency Guidelines have no provisions for this approach.

Thats what I thought, and why I didn't allow this when we implemented the new guidelines.

Thanks for the input, Dan!