Answer by Randy Carey: If there are instances in which you are not reviewing all appraisals and evaluations, you should have those exception clearly outlined in your policies.
From the 2010 Interagency Appraisal and Evaluation Guidelines:
XV. Reviewing Appraisals and Evaluations
The Agencies' appraisal regulations specify that appraisals for federally related transactions must contain sufficient information and analysis to support an institution's decision to engage in the credit transaction. For certain transactions that do not require an appraisal, the Agencies' regulations require an institution to obtain an appropriate evaluation of real property collateral that is consistent with safe and sound banking practices. As part of the credit approval process and prior to a final credit decision, an institution should review appraisals and evaluations to ensure that they comply with the Agencies' appraisal regulations and are consistent with supervisory guidance and its own internal policies. This review also should ensure that an appraisal or evaluation contains sufficient information and analysis to support the decision to engage in the transaction.
Answer by Dan Persfull: There are exemptions for a transaction that is eligible for sale to a GSE and the appraisal is in compliance with their appraisal standards or loans that are guaranteed by a government agency.
You can find these exemptions under Appendix A, #'s 9 & 10.
First published on BankersOnline.com 1/7/13