Seems like this question has probably been answered long ago but I couldn't come up with the right combination of key words in the search to find my answer.

If a bank performs an in-house evaluation of the property value for a TRID loan (loan purpose of home equity), should we be disclosing that value on the CD as "Appraised Prop. Value" or "Estimated Prop. Value?" The interpretation to 1026.38(a)(3)(vii) seems to indicate using Estimated Prop. Value if no appraisal, but appraisal is not defined as far as I could tell. I take appraisal to mean certified appraisal by a licensed appraiser, which leads me to think we should use estimated prop value for in-house evaluations. But, the commentary also says "In transactions where there is no seller, such as in a refinancing, 1026.38(a)(3)(vii)(B) requires the creditor to disclose the appraised value of the property. To comply with this requirement, the creditor discloses the value determined by the appraisal OR valuation used to determine approval of the credit transaction. If the creditor has not obtained an appraisal, the creditor may disclose the estimated value of the property." The way I read that, you could interpret it to mean that either an appraisal or another valuation would be disclosed as "appraised prop. value." On the other hand, it does state "if the creditor has not obtained an appraisal, the creditor may disclose the estimated value of the property." I think I have overanalyzed this to the point I just need someone else's thoughts on this.

You will find answers leaning both ways. I still continue to call ours 'estimated Property Value' because our in-house evaluator is not certified,..nor is the evaluation anything near like what a true property appraisal report is... I just can't consciously call it the more official 'appraised value'.

You would think that the folks writing final rules would articulate that "Appraised means by a certified appraiser, and all else is Estimated". It wouldn't be that difficult. I used to write rulemaking in another life. Dept of Transportation. Much easier.