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Interagency Appraisal and Evaluation Guidelines

 

The revised Interagency Appraisal and Evaluation Guidelines, published in December 2010, actually were not issued as a result of Dodd-Frank; they exist separate and independent of Dodd-Frank. They were proposed in 2008, two years before Dodd-Frank, and finalized just after Dodd-Frank.

GAO’s Involvement

 

One of the things Dodd-Frank did was task the U.S. Government Accountability Office (GAO) with writing two reports to Congress in which they were critical of the oversight of state appraisal boards and appraisers.

Condition of Property

 

If you’re doing evaluations internally, you need to think about how you are getting information on physical condition. The term “average condition” is frowned upon, especially if it’s unsupported and assumed.

What Should an Evaluation Include?

 

In many cases, standard operating procedures for evaluations that were once considered acceptable to regulators are now deemed wholly unacceptable, due to Dodd-Frank.

The Review Process

 

There is a mandate that all evaluations and appraisals be reviewed prior to the final credit decision. Worth noting is an expectation on the part of the regulator that the person who does the evaluation has the appropriate education, experience and competence, specifically with respect to the property type, the risk and the complexity involved in the transaction.

Get Your Free Copies

 

One consumer protection regulation that will impact how you perform evaluations on the residential side is Dodd-Frank's Section 1474: Equal Credit Opportunity Act (ECOA) § 701(e), an amendment requiring a free copy of an appraisal/valuation.

Compliance Guides for Dodd-Frank Appraisal Rules

 

Late yesterday, the CFPB published compliance guides for its ECOA Valuations Rule and the TILA Higher-Priced Mortgage Loans (HPML) Appraisal Rule.  Both rules were finalized in January of this year and take effect in January of 2014.

Best Practices when working with appraisers

 

Appraiser Blacklisting and Defamation

Three Predictions for Your Next Regulatory Exam

 

Three Predictions for Your Next Regulatory Exam

Overview of the New Higher-Risk Mortgage Loan Requirements

 
AMC Appraisal Management

In a blog post last week, we alerted you that the agencies had released a new, 211-page proposal to implement Dodd-Frank Section 1471, which added Section 129H to the Truth in Lending Act.  That section imposes tougher appraisal requirements on higher-risk mortgage loans.  The next day, we circulated our preliminary analysis of the proposal. 

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