Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
Can our bank use an appraisal that has been addressed to another bank regarding a commercial loan under $250,000, provided that it has all the required criteria for an acceptable appraisal? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Can our bank use an appraisal that has been addressed to another bank regarding a commercial loan under $250,000, provided that it has all the required criteria for an acceptable appraisal?

—

by

Yes, your bank may use an appraisal addressed to another bank, provided that the other bank directly engaged the appraiser, the appraiser has no direct or indirect interest in the property or the transaction, and the appraisal conforms to FDIC appraisal regulations and is otherwise acceptable.

We also note that your bank may use an evaluation in lieu of an appraisal for certain real estate related transactions, including transactions with a value of $250,000 or less and business loans with a value of $1 million or less that are not dependent on the sale of or income from the real estate as the primary source of repayment.

For resources related to our guidance, please see:

  • FDIC Appraisal Regulations, 12 CFR 323.5 — Appraiser Independence (“A regulated institution also may accept an appraisal that was prepared by an appraiser engaged directly by another financial services institution, if: (i) The appraiser has no direct or indirect interest, financial or otherwise, in the property or the transaction; and (ii) The regulated institution determines that the appraisal conforms to the requirements of this subpart and is otherwise acceptable.”)
  • Interagency Appraisal and Evaluation FAQs (“A regulated institution may accept an appraisal transferred from another regulated institution or from a financial services institution (that is, a non-regulated institution), provided 1) the appraiser is engaged directly by the institution transferring the appraisal, 2) the appraiser has no direct or indirect interest in the property or transaction, 3) the existing appraisal or evaluation remains valid, and 4) the regulated institution determines that the appraisal conforms to the agencies’ appraisal requirements and interagency guidelines and is otherwise appropriate.”)
  • FDIC Appraisal Regulations, 12 CFR 323.4 (Enumerating minimum appraisal standards)
  • FDIC Appraisal Regulations, 12 CFR 323.3 (Stating when appraisals are required and listing exceptions to the requirement, including exceptions for transactions with a value of $250,000 or less and business loans with a value of $1 million or less that are not dependent on the sale of or income from the real estate as the primary source of repayment)