Thread Starter: Anonymous
Title: Re: Appraisals
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I have read Regulation Z 226.42 a dozen times. From what I take, it says that a covered person is prohibited from the following (226.42(c)):
1. Seeking to influence a person preparing a valuation to report a certain value on the home.
2. Withhold payments (or threaten) to withhold payments.
3. Imply that future jobs depend upon a valuation
4. Exclude valuators due to them not reporting certain values on a home.
5. Conitioning payment based upon a valuation.
It may be a fine line, but where in the summarized points above does it say that a loan officer can not order the appraisal. It just states that they can't do any of the points above.
Hypothetically speaking, if you have controls in place to monitor the appraisal ordering process, couldn't you have a loan officer order an appraisal and still not violate Regulation Z?
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