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#1449605 - 09/29/10 03:22 PM Appraisal Requirements for OREO/REPO
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
Does Florida have a requirement for the frequency in which appraisals must be obtained for bank owned assets, specifically residential real estate and non-residential real estate (i.e. manufactured homes without land)?

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#1449646 - 09/29/10 03:55 PM Re: Appraisal Requirements for OREO/REPO Many Hats
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
The only thing in the Statutes is found here: 655.60 Appraisals.
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#1449773 - 09/29/10 05:37 PM Re: Appraisal Requirements for OREO/REPO rlcarey
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
I find it funny that the statute doesn't really mention anythng either about the required frequency. Go figure.

Meanwhile, FWIW, following is the answer I received from our CPA:

The "FAS" codification has changed so the FAS 114 (which used to relate to impairment) and FAS 105 don't technically exist anymore.

FASB ASC 310-40 establishes guidance on the accounting for the financial reporting of foreclosed assets
FASB ASC 310-40-30 speaks to the initial measurement of OREO

FASB ASC 360-10-35-43 relates to subsequent measurement, but doesn't note how often a property should be valuated. It simply notes that the asset should be measured at the lower of its carrying amount or fair value less cost to sell. Fair value obviously changes through time especially now-a-days. So, the general rule of thumb for auditors and regulators is to value OREO at least on an annual basis. This does not necessarily have to be an appraisal (cost prohibitive for many banks) though that is the most common way.

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