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What Communications are Allowed with an Appraiser Hired by the Lender Under the Lending Guidelines in the Dodd-Frank Act?

07/01/2019 2:08 PM | Maureen Connolly (Administrator)

What Communications are Allowed with an Appraiser Hired by the Lender Under the Lending Guidelines in the Dodd-Frank Act?

  • Appraisers can talk with builders, brokers, agents, and sellers
  • Builders, brokers, agents, and sellers can provide the appraiser with documents
  • Builders, brokers, agents, and sellers can accompany appraiser on the inspection
  • Appraisers cannot be pressured by loan officer or others involved in the process to arrive at a value conclusion or to omit important facts

Few lenders have seen or heard of the Residential Green and Energy Efficient Addendum and some may claim that they have to pick appraisers off their rotation lists.

The Residential Green and Energy Efficient Addendum puts the lender on notice that you have a complex appraisal assignment and they need hire a competent appraiser Dodd-Frank banking reform act prohibits them from involvement appraiser hiring. The prohibition pertains to loan officers and others whose income is tied to the loan, not their purchasing department or a hired Appraisal Management Company (AMC).

The lender or AMC should have some general guidelines on choosing appraisers and once they have made their choice, the appraiser should examine [the assignment] and make the final competency decision.

“Lenders and AMCs are required to have appraiser panels with more than one appraiser. They are charged with hiring the appraiser with competency in the property type and geographical area, NOT the next one on the rotation list, NOT the cheapest, NOT the most conservative, and NOT the fastest.

Quotes: Sandra K. Adomatis, SRA, LEED Green Associate

With the routine provision of appropriate data documenting energy efficiency and renewable energy features along with loan applications lenders and AMCs will start asking about an appraiser’s course work and experience in valuing high performance or green properties.

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