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#473865 - 12/21/05 10:34 PM Internal Appraisal Review and Reg. B
Geoz Offline
100 Club
Joined: Apr 2003
Posts: 148
Colorado
The definition of an "appraisal" for purposes of providing a copy under 202.14(c)1.iii includes an internal review document if it reflects a different value than the 3rd party appraisal. The way this reads, it would seem to include the bank's internal appraisal review (under these circumstances). If this is correct, then a copy of the appraisal as well as the review document would be needed? Am I missing something? We're going round and round on this - I would really appreciate another opinion.

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Lending Compliance
#473866 - 12/22/05 03:59 AM Re: Internal Appraisal Review and Reg. B
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,277
Galveston, TX
Sounds like you got it. If you have an appraisal, but you change the value to something else - you have to provide them the information and paperwork you created to justify it.
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