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#2230997 - 02/13/20 06:38 PM Appraisals
debbie sluder Offline
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Joined: Oct 2011
Posts: 50
We have a client that had her home appraised a few months ago by a certified appraiser, one that is on our bank's appraiser list. The appraisal is made to her, since she engaged the appraiser herself. She has applied for a mortgage loan and doesn't want to pay for another appraisal since the one she has is just 3 months old. I know the client is not suppose to engage the appraiser. What are our options? Can we have the appraiser re-direct the appraisal to our bank? Any suggestions?

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2230998 - 02/13/20 06:41 PM Re: Appraisals debbie sluder
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Your only option is to order another appraisal. Any other option would be a direct (and willful) violation of the appraisal rules.

An institution’s use of a borrower-ordered or borrower-provided appraisal violates the Agencies’ appraisal regulations.
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#2231001 - 02/13/20 07:01 PM Re: Appraisals debbie sluder
rlcarey Online
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rlcarey
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Galveston, TX
And the appraiser would violate the USPAP if they readdressed that appraisal to another party beside her.
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#2231200 - 02/18/20 07:18 PM Re: Appraisals debbie sluder
John Burnett Offline
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John Burnett
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Cape Cod
I'll tie this up a a big red bow with a statement of the obvious -- Although the bank must comply with the appraisal guidelines and obtain a valuation of the property, if the bank pays for an appraisal, it isn't required to pass the cost on to the borrower.
Last edited by John Burnett; 02/18/20 07:21 PM. Reason: clarity
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#2233588 - 03/24/20 07:00 PM Re: Appraisals John Burnett
CRAzy_lady Offline
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Joined: Dec 2012
Posts: 56
Here's a different scenario - If the bank is making a loan for a bank-owned property and using an appraisal we obtained previously (and therefore not requiring a new one for this loan), am I correct in thinking we do not have to comply with the Reg B rules to provide an appraisal disclosure and the appraisal?

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#2233590 - 03/24/20 07:03 PM Re: Appraisals debbie sluder
rlcarey Online
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rlcarey
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Galveston, TX
Why would you not? The borrowers never got it.
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#2233592 - 03/24/20 07:05 PM Re: Appraisals rlcarey
CRAzy_lady Offline
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Posts: 56
The bank obtained the appraisal prior to this borrower's application.

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#2233595 - 03/24/20 07:09 PM Re: Appraisals debbie sluder
rlcarey Online
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rlcarey
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Galveston, TX
a copy of all appraisals and other written valuations developed in connection with an application for credit

If you are using it - it was developed - regardless of when you ordered it.
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