we will not be obtaining a new appraisal in connection with his current application nor will we be obtainng a recertification or update from the appraiser or conduct our own evaluation.
You have to validate the existing appraisal is still valid. With the appraisal only being 3 months old that should be relative simple but IMO you still need to document its validity.
XIV. Validity of Appraisals and Evaluations
The Agencies allow an institution to use an existing appraisal or evaluation to support a subsequent transaction in certain circumstances. Therefore, an institution should establish criteria for assessing whether an existing appraisal or evaluation continues to reflect the market value of the property (that is, remains valid). Such criteria will vary depending upon the condition of the property and the marketplace, and the nature of the transaction. The documentation in the credit file should provide the facts and analysis to support the institution’s conclusion that the existing appraisal or evaluation may be used in the subsequent transaction. A new appraisal or evaluation is necessary if the originally reported market value has changed due to factors such as:
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The opinions expressed are mine and they are not to be taken as legal advice.