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#2099172 - 09/19/16 06:00 PM OREO
INOH Offline
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Joined: Jul 2012
Posts: 345
Northeast
What is the requirements on OREO’s appraisals in order to support the market value? I have one that the appraisal is 12 yrs old… property has just been moved to OREO and there is no contract to sell or anything like that.
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Audit
#2099178 - 09/19/16 06:18 PM Re: OREO INOH
edAudit Offline
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edAudit
Joined: Jul 2008
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A: In accordance with the regulatory appraisal exemption for an existing extension of credit
in the Federal Reserve Board's appraisal regulation, [Footnote6
-- See the Board's Regulation H for state member banks (12 CFR 208, subpart E) and the Board's Regulation Y for holding companies (12 CFR 225, subpart G). End of Footnote 6.]
a regulated institution is required at
minimum to obtain an evaluation when a property is transferred to OREO through foreclosure or a deed in lieu of foreclosure. Although the appraisal regulation's minimum requirement is an evaluation, the regulated institution may decide to obtain an appraisal, considering the type, complexity, use, and location of the property, as well as current market conditions. Refer to SR letter 10-16, "Interagency Appraisal and Evaluation Guidelines," for a discussion of the development and content of an evaluation.

http://www.federalreserve.gov/bankinforeg/srletters/sr1210a1.pdf
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#2099179 - 09/19/16 06:20 PM Re: OREO INOH
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
You also might need to refer to State law also, if you are State chartered.
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#2099209 - 09/19/16 07:15 PM Re: OREO INOH
INOH Offline
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Joined: Jul 2012
Posts: 345
Northeast
Thanks! the bank is regulated by the OCC and is not a state chartered bank.
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#2099216 - 09/19/16 07:27 PM Re: OREO INOH
edAudit Offline
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edAudit
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12 CFR 34.85 and 12 CFR 160.172 require national banks and FSAs, respectively, to obtain
an appraisal or evaluation, as appropriate, to substantiate the market value of each parcel
upon transfer to OREO.6 If a bank has a valid and compliant appraisal or evaluation that was
previously obtained in connection with the real estate loan, however, the bank does not need
to obtain a new appraisal or evaluation to comply with these regulations. Section XIV,
“Validity of Appraisals and Evaluations,”

http://www.occ.gov/publications/publications-by-type/comptrollers-handbook/a-oreo.pdf

You are in luck with the OCC they have a handbook for OREO
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#2099337 - 09/20/16 01:47 PM Re: OREO INOH
INOH Offline
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Joined: Jul 2012
Posts: 345
Northeast
Thank you, I found it yesterday.
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