Auditing our appraisal review format and came across two forms that triggered a Reg B question. Each of these forms (from a third party vendor for the review) more or less states a concurrence with the value that is reported on the appraisal. If these loans were subject to the delivery requirement for this section of Reg B, what are your thoughts on these reviews? Our internal and other outsourced reviews have not been delivered as they fall under the list on comment 14(b)(3)Other Documentation as "internal documents that merely restate the estimated value....." But now we have some paper in the file that isn't just a restatement but a concurrence. Yea, I know....whole other can of worms opened by this statement on the forms, but a few of us are now tossing around the Reg B implications. I'm leaning towards it as a document that has a statement of value on it. After all, if the reviewer could concur with the value, couldn't he also make a statement of another value?

I knew outsourcing wasn't going to be as easy as it looked.

As this is in relation to Appraisal Review take a look at the following further down in the commentary:

vi. Appraisal reviews that do not include the appraiser's estimate of the property's value or opinion of value.

I do fill in occasionally in reviewing appraisals and evaluations at our bank and as part of the process I could disagree with the value, but that does not mean I can provide a value. All that mean is we need to get another opinion of value from a different qualified appraiser or evaluator. That second appraiser or evaluation would also be subject to Reg. B, but the review forms would not be. Maybe checking to see if the person filling out the form can state a value if they disagree and if that value is based on reevaluation of the property may help figure out your conundrum.

Good Luck.

Thanks Kat.

I think I will start by asking the reviewer what they would do if they disagreed with the value. If they can write down a different figure, and then have valued the property differently, I think we are in trouble. Our previous in-house form just had the reviewer acknowledge that the appraisal report met our conditions to be acceptable for use. And that was all.

Thanks for helping me think through this logically.