Posted By: Anonymous
Influencing Appraisals - 06/19/13 02:48 PM
Which regulation(s) govern the extent to which a loan officer can contact the appraiser to discuss issues raised by the appraisal. We have an issue where there is a question about including certain square footage in Gross Living Area when that footage is only heated, not cooled, and want to know if it is O.K. for the MLO to ask the appraiser if it was included by mistake.
Posted By: rlcarey
Re: Influencing Appraisals - 06/19/13 04:01 PM
Whoever (as an independent party) is in charge of appraisal review should be asking such a question, as depending on the answer, it could be a flawed appraisal. The loan officer should not have direct contact with the appraiser. From the guidelines:
An institution should establish reporting lines independent of loan production for staff who administer the institution's collateral valuation program, including the ordering, reviewing, and acceptance of appraisals and evaluations.
an institution should be able to demonstrate clearly that it has prudent safeguards to isolate its collateral valuation program from influence or interference from the loan production process
An institution's policies and procedures should specify methods for communication that ensure independence in the collateral valuation function.
I am going to need to use that info in the near future. RLCarey, where did you quote that from?
Thanks in advance
Posted By: edAudit
Re: Influencing Appraisals - 07/30/13 06:57 PM
I think it is his own.
agreed you may wish to pick something out of here (page 3):
http://www.fdic.gov/news/news/financial/2010/fil10082a.pdf