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#2245125 - 11/04/20 08:03 PM Appraisal Waiver and Property Value
Luv2run Offline
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Joined: Jan 2015
Posts: 610
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?
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#2245132 - 11/04/20 08:54 PM Re: Appraisal Waiver and Property Value Luv2run
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
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.
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#2245150 - 11/04/20 10:16 PM Re: Appraisal Waiver and Property Value Luv2run
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,395
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.

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#2245318 - 11/09/20 08:23 PM Re: Appraisal Waiver and Property Value Luv2run
Luv2run Offline
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Joined: Jan 2015
Posts: 610
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.
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#2245319 - 11/09/20 08:29 PM Re: Appraisal Waiver and Property Value Luv2run
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
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.
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#2245429 - 11/12/20 03:36 PM Re: Appraisal Waiver and Property Value Luv2run
Luv2run Offline
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Joined: Jan 2015
Posts: 610
Thank you all. Always nice to have backup before I approach the troops!
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