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#2096507 - 09/01/16 12:27 PM Reg B Appraisal Notice-Auditor Question
mdog76 Offline
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We had an auditor go through our loan files and she went through some old files, some dating back to 2004 ha! What Reg B appraisal notice would have been in effect in 2004? Would it have been the one that said "if you wish to obtain a copy of the appraisal please contact us........"?

Thank you

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Lending Compliance
#2096525 - 09/01/16 01:26 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
https://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR

Go there and pick your year and see what Reg. B says.
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#2096554 - 09/01/16 02:41 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
mdog76 Offline
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We had an auditor hit us on not having a REG B notice in a file from 2004. 12 years after the fact, how do we even address it? Can't go back and get it signed since the notice language has been changed since. Why go back and cite something from 12 years ago?

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#2096562 - 09/01/16 03:18 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
JSD Offline
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JSD
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USA
Another good reason to stick to the retention schedules - never have more years than required!

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#2096569 - 09/01/16 03:27 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
mdog76 Offline
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The loan is still active. I'm not sure of how the loan was selected in the sample but I'm the one stuck trying to figure out something from when I was still in college ha!

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#2096635 - 09/01/16 06:14 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
rlcarey Online
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rlcarey
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Galveston, TX
Auditor - what type of auditor - internal or external?

Whoever it is, tell them to get a life. Who needs anyone looking at twelve year old loans. They just wasted the bank's valuable resources. You perform audits to identify current weaknesses not to play gotcha on something that happened twelve years ago that poses no current risk to the bank.

I would suggest that whoever this auditor works for, needs to become an ex-auditor pronto.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096660 - 09/01/16 06:47 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
mdog76 Offline
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Its an external auditor.

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#2096666 - 09/01/16 07:00 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You better have whoever signed the engagement letter at your bank with this firm talk to their management and tell them that the bank will be looking for a new audit firm if that represents the quality of work that is going to be performed. It comes down too, the Bank is basically paying them to waste your time. Don't let this stand.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096686 - 09/01/16 08:08 PM Re: Reg B Appraisal Notice-Auditor Question mdog76
happyauditor Offline
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happyauditor
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NY
Look at what the scope of work was agreed upon...did you ask for a comprehensive review of record retention of required loan documents? Silly, since nothing you can do to fix it, but maybe that is what was requested in the scope of work. I agree it was a waste of time, just guessing on why they would have even looked at a 12 year old loan for documents connected with the origination of the loan.
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