I need some thoughts on appraisals. Hope I explain this correctly.
We have some mortgage loans that we are underwriting under Fannie Mae guidelines. It is not our intention at time of application to sell the loan. We are underwriting it that way incase we ever decide to sell it. It would stay on the banks books until that time comes. Due to the bank using Fannie Mae guidelines, if Fannie Mae would not require an appraisal, we are not requiring an appraisal to be preformed. Do you think this would be in compliance with the appraisal regulation? What are your thoughts?

It depends on the loan amount. Residential real estate transactions with loan amounts greater than $400,000 require appraisals unless the transaction fits into one of the exceptions.

Yes we either do an appraisal or evaluations depending on the loan amount. So would you say we need something(appraisal or evaluation) since we are servicing the loan and not Fannie Mae, unless we decide later to sell it.

Transactions that Qualify for Sale to, or Meet the Appraisal Standards of, a U.S. Government Agency or U.S. Government-sponsored Agency continue to have an exemption from the interagency appraisal guidelines. You do have to make sure that they actually qualify for sale, including all documentation, not that you just ran them through DU.

10(i) An institution that relies on exemption 10(i) should maintain adequate documentation that confirms that the transaction qualifies for sale to a U.S. government agency or U.S. government-sponsored agency. If the qualification for sale is not adequately documented, the transaction should be supported by an appraisal that conforms to the Agencies’ appraisal regulations, unless another exemption applies.

10(ii) To qualify for this exemption, transactions that do not conform to all of Fannie Mae or Freddie Mac underwriting standards, such as jumbo or other residential real estate loans, must be supported by an appraisal that meets these government-sponsored agencies’ appraisal standards for the applicable property type and is documented in the credit file or reproducible.