What do you think of the following?
A lending area wants to accept appraisals that were ordered by mortgage brokers (on the approved list but NOT paid by the bank) from appraisers (also on approved list). The lending area thinks this will be okay because they will instruct the appraiser to "rewrite" the appraisal to us and pay a fee for him to do so. The appraisal will come in with everything the same but addressed to us, just as if we were the original client.
I personally think this is a violation of FIRREA because the appraisal would not be ordered by us, our agent, or another financial institution. I believe it is also a USPAP violation by the appraisers because the appraiser will not be sending a letter revealing the relationship with the original client who ordered the appraisal.
Has anyone had any experience with this? I have reviewed the appraisal requirements, USPAP and OCC bulletin B-00-33 and think this process would be a violation.
[This message has been edited by kblanchard (edited 02-06-2001).]