Thread Options
#2245125 - 11/04/20 08:03 PM Appraisal Waiver and Property Value
Luv2run Offline
Gold Star
Joined: Jan 2015
Posts: 417
On some of our investor loans, we are not obtaining an appraisal. We do however work with an estimated property value for underwriting purposes. I am thinking we would report that estimated value for HMDA purposes.......others disagree and feel we should not based on the fact that we do not have an appraisal....anyone?
_________________________
If at first you do succeed....try something harder
-fortune cookie

Return to Top
HMDA

   
HMDA Academy
#2245132 - 11/04/20 08:54 PM Re: Appraisal Waiver and Property Value [Re: Luv2run]
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
What did you use for underwriting purposes?

Paragraph 4(a)(28).

1. General. Except for partially exempt transactions under § 1003.3(d), § 1003.4(a)(28) requires a financial institution to report the value relied on in making the credit decision. For example, if the institution relies on an appraisal or other valuation for the property in calculating the loan-to-value ratio, it reports that value; if the institution relies on the purchase price of the property in calculating the loan-to-value ratio, it reports that value.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2245150 - 11/04/20 10:16 PM Re: Appraisal Waiver and Property Value [Re: Luv2run]
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,251
FNMA DU will randomly allow appraisal waivers on property that the value listed is supported by information in their data base. When that occurs, I'm reporting that value on my HMDA LAR.

Return to Top
#2245318 - 11/09/20 08:23 PM Re: Appraisal Waiver and Property Value [Re: Luv2run]
Luv2run Offline
Gold Star
Joined: Jan 2015
Posts: 417
We use an estimated value on the refinance transactions, and the sales price for purchase transactions. I am of the mindset that we would report these amounts.
_________________________
If at first you do succeed....try something harder
-fortune cookie

Return to Top
#2245319 - 11/09/20 08:29 PM Re: Appraisal Waiver and Property Value [Re: Luv2run]
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 38,772
Cape Cod
Clearly, you aren't making the loan without at least an estimate of value, whether it's the purchase price, a value provided by FNMA (see Truffle Royale's post ^^^) or an in-house estimate. Without it, you could not responsibly make the loan. Whatever value that is is what HMDA requires you to report.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2245429 - 11/12/20 03:36 PM Re: Appraisal Waiver and Property Value [Re: Luv2run]
Luv2run Offline
Gold Star
Joined: Jan 2015
Posts: 417
Thank you all. Always nice to have backup before I approach the troops!
_________________________
If at first you do succeed....try something harder
-fortune cookie

Return to Top