I've not worked alot with the new appraisal standards so I'm wondering if anyone can help me with some questions.
We had about 8 different lake property lots in OREO. We had a buyer for all of them and we did a loan for the buyer to purchase all 8 lots. Now, we had current appraisals/evaluations on all but two of the lots. The other 2 lots we had evaluations, but they were about 17 months old. The age of these apparisals in todays given environment should be a no-no, but nevertheless, it happened. So, what is the regulatory age limit for appraisals/evaluations to be reused? Second, if the value of the 6 appraisals/evaluations on the other lots combined was enough to cover the loan amount, is there any violation of not having a current appraisal/evaluation on these 2 other properties, or do we have to have a current appraisal/evaluation on each property that secures the loan?

Another question.....does it matter that these are OREO properties? Can this be considered a subsequent transaction that would only require an evaluation? By the way, the loan amount is 1.6MM