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#666279 - 01/15/07 09:43 PM GLBA & Appraisers
Anonymous
Unregistered

Is it typical to have an appraiser sign a privacy agreement before using them for a loan? If so does this have to be done annually? We do not have a required appraiser. Appraisers hare chosen on a per case basis.

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#666504 - 01/16/07 04:36 PM Re: GLBA & Appraisers Anonymous
Bear Collector, CRCM Offline
Diamond Poster
Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
Unless your Privacy Notice states that you share confidential information with unaffiliated 3rd parties and gives your consumer customers the right to opt-out, you need to be sure that any appraiser you use agrees to protect your consumer's information. At the very least, you need to be sure that appraisers sign a confidentiality agreement containing all the GLBA and FACTA required disclosures. Although this is presumably a transaction your customer has requested, what assurance do you have that the appraiser won't sell your customer's confidential information to another 3rd party? How will your appraiser notify you if someone breaks into his/her office and steals a laptop containing your customer's information? How does your appriaser agree to dispose of confidential information? If you don't have a written agreement, you are probably violating your own privacy policy, particularly if you state in your Notice to your consumers that the vendors you contract with agree to abide by your bank's confidentiality policy, and treat your customer's NP information the same way you do.
There is no reason you can't get this at the time you order an appraisal, although it may hold up the process. If your chosen appraiser refuses to sign, pick another one. I am sure you are not the only bank in town requiring this.
BC
_________________________
Being kind is more important than being important.

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#666928 - 01/16/07 10:31 PM Re: GLBA & Appraisers Bear Collector, CRCM
Anonymous
Unregistered

Does anyone have an example of a contract/agreement that could be sent when engaging an appraiser?

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