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#2272974 - 07/18/22 12:05 PM Re: When to include FCRA disclosure(s) bziegler
Monster Offline
Gold Star
Joined: Sep 2015
Posts: 489
Yes, thank you Randy!

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#2273031 - 07/19/22 02:40 PM Re: When to include FCRA disclosure(s) Monster
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,637
Originally Posted by Monster
Inherent Risk: "The issue of whether an appraiser is such a third party has been the subject of disagreement."

I think that may have been true in the past. I don't think there is very much disagreement anymore. There's a pretty strong consensus behind what randy is saying.


I've been reading through older (2003-2018) threads related to this, and I have to say I really thought there used to be 2 (more equal in size) camps on this, around 5+ years ago, but haven't been able to find any supporting posts of this "memory." It seems clear to me now, even though I worked for a few banks that would check the 3rd party box when denying due to the appraisal value, that the vast majority, and myself, see the appraisal as not relating to credit capacity. Those banks never got dinged for it while I was with them, I'm confident in saying... but it likely wasn't a priority of examiners. I also think the comparison to ATR isn't too much of a stretch.

Providing a link (members only) to ABA that also agrees, to give another example outside of BOL.

https://www.aba.com/banking-topics/...isclosures-inadequate-property-appraisal

Yes, I agree I doubt examiners look at this in any detail. They are generally just making sure you check the box for the consumer report and that you get the credit score, etc. section correct.

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