ABA Banking Journal - January 2011 - (Page 38)
compliance clinic | real-estate appraisals
New appraisal guidelines demand close look
by george r.mann and robert s.ely
ow up to date are you on the federal appraisal rules? As a check, consider the following fairly common practice: A borrower brings one of your lenders an appraisal that was performed for another bank. You accept it and add it to the loan file. If you’re OK with that, that’s just one reason your bank had better get up to speed, because you’d be wrong. Getting on the right pages In December 2010 the five federal banking regulators issued a statement titled “Interagency Appraisal and Evaluation Guidelines.” These guidelines supplement existing guidance and rescind the 1994 “Interagency Appraisal and
Evaluation Guidelines” (FIL-74-94); “Statement on Appraisal Standards” (FIL-20-2001); “Interagency Statement on Independent Appraisal and Evaluation Functions” (FIL-842003); and the 2006 “Revisions to Uniform Standards of Professional Appraisal Practice” (FIL-53-2006). The new document is full of things anyone who relies on appraisals should be clear about, from the board to the newest loan officer. The scenario we opened with is covered in Section VI, “Selection of Appraisers or Persons Who Perform Evaluations.” This section emphasizes the importance of appraiser competency for a particular assignment relative to both the property type and geographic market and
| aba banKIng JoUrnal | january 2011
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