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#2042169 - 10/02/15 03:59 PM ECOA Appraisal - Commercial Loans to Same Builder
BFaith75 Offline
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Joined: Dec 2012
Posts: 105
If multiple commercial loans are made to the same builder over a period of time and the same master appraisal is used based on the floor plan of the unit, is the bank required to provide a copy of the same appraisal for each of the subsequent transactions, or will the ECOA requirement to provide a copy of the appraisal be satisfied by providing the master appraisal with the initial loan?
Last edited by BFaith75; 10/02/15 04:01 PM.
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#2042184 - 10/02/15 04:30 PM Re: ECOA Appraisal - Commercial Loans to Same Builder BFaith75
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
How does "it depends" sound? In our shop, the original appraisal was only developed in conjunction with the first loan. However, we develop an in-house evaluation for each subsequent loan that takes into consideration the use of the value of the existing appraisal given the location of the second lot, time passed, whatever. That assessment of value is developed in conjunction with the second loan and would be provided.

I hope that helps.

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#2042203 - 10/02/15 05:07 PM Re: ECOA Appraisal - Commercial Loans to Same Builder Cornfed Turtle
BFaith75 Offline
100 Club
Joined: Dec 2012
Posts: 105
Thanks for your response. Has your practice been reviewed by your regulator yet? Also, what if we don't develop an in house evaluation for each loan? Can anyone weigh in with experience in that type of situation?

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#2042208 - 10/02/15 05:24 PM Re: ECOA Appraisal - Commercial Loans to Same Builder BFaith75
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
You are welcome and yes, we've had "them" in the house recently. If we don't develop the valuation report (appraisal or evaluation) in conjunction with a loan that meets the requirements, we don't give it out. We do the notice...but don't give out the report from another loan. It has to developed in conjunction with that loan to head out the door. (Much easier to track on our end!)

But, perhaps, we shall hear from someone with your exact scenario.

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