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#2259236 - 09/03/21 02:35 PM Using Same Appraiser for Renovation of Property
Wonderofitall Offline
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Appraiser A appraised several duplexes in 10/20 for another bank. Borrower has made significant improvements to the properties and has applied for a new loan using these as collateral. We would like to use the same appraiser because the appraisals would likely be less costly and delivered more quickly. We use an AMC to select appraisers. If we were to suggest this appraiser to the AMC, would that violate any appraiser independence rules?
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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2259240 - 09/03/21 02:40 PM Re: Using Same Appraiser for Renovation of Property Wonderofitall
rlcarey Online
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I am not sure why you think that you are going to get a price break in this market place. It is a totally separate assignment and the appraiser would be required to start from scratch.
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#2259241 - 09/03/21 02:44 PM Re: Using Same Appraiser for Renovation of Property Wonderofitall
Wonderofitall Offline
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Price break anticipated because my glass is always half-full. So, no independence issues with us suggesting the appraiser to the AMC?
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#2259242 - 09/03/21 02:55 PM Re: Using Same Appraiser for Renovation of Property Wonderofitall
rlcarey Online
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It sort of defeats the purpose of using an AMC. Anyone that is involved in the transaction should not be making that request. Also, read your board approved appraisal policy to make sure they would allow such an exception. Plus, if the other loan was through another bank, how are you even aware of what appraiser was used?
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#2259246 - 09/03/21 03:44 PM Re: Using Same Appraiser for Renovation of Property Wonderofitall
Wonderofitall Offline
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A new appraisal was ordered per our Bank's policy.
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#2259262 - 09/03/21 07:18 PM Re: Using Same Appraiser for Renovation of Property Wonderofitall
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As Randy noted, "suggesting" the appraiser you should get defeats the purpose of the AMC and independence. I haven't reviewed an AMC agreement, but it shouldn't have an optional selection box for who you want. In reality, if the appraiser is familiar with the property and the market area in general, their job should be easier and you may get a document sooner, but I wouldn't hold my breath that you'd get a price break. And if you did, I'd be afraid of the audit report that says the bank selected this appraiser and received a discount on the cost. What does that say?
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