I'm sorry if someone already asked this, but I'm unable to locate a post on point.

It's my understanding that internal documents that merely RESTATE the value are NOT subject to disclosure; however, this seems to apply to documents that would be prepared AFTER the appraisal is received, such as the appraisal review.

Do we have to provide the applicant a copy of the credit memo that was approved subject to the appraisal coming in at or above a certain value if the appraisal comes in at a different value (higher or lower)?

I don't think you provide the credit memo at all. The credit memo doesn't value the property. It merely states the value of collateral needed for your bank to offset the risk in that loan amount.

My read is that any documents discussing valuation or credit risk do not need to be provided. Only those documents that actually value the property must be provided.

Watch that your appraisal report reviewers aren't turning themselves into appraisers.

Ok. I understand your point that "only those documents that actually value the property" must be provided. However, I attended a seminar and the presenter indicated that if the credit memo indicated a different value than the appraisal report that the credit memo was subject to disclosure. An example provided was that the appraisal came in at a certain value and the bank discounted it for some reason. The presenter stated that because the credit memo had a different value we would need to provide it. I'm not certain that this would happen at our bank, but I need to make sure I understand this.

As for my original question, I am comfortable now that the approved credit memo would not be subject to disclosure as it would be indicating (as you stated) what the appraised value would need to be in order for the bank to proceed. The credit memo would not be valuing the property.

Thanks for the response.

Now it's my turn to see your point!

And this is where you have to watch your reviewers becoming appraisers, too. I always tell the reviewers that they are reviewing the report only. If they don't agree with the valuation (because they see some flaw in the process or whatever) then send it back to the appraiser. If your credit memo or your appraisal review form values the property differently, I think it does become subject to disclosure. And we don't want to start valuing properties; that's what appraisers are for.

Agreed!