Topic: Appraisals and Valuation
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Our institution recently grew to over $250 million in assets. Since we have crossed that threshold, do we have to make changes to our appraisal process? We currently use a third party company to prepare our appraisals.
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After crossing the $250 million asset threshold, your institution is subject to heightened requirements to avoid conflicts of interest when your institution’s employees perform or review property valuations. 12 CFR 1026.42(d)(2). Even though your institution’s valuations are produced by a third party, the employees who review those valuations are subject to Regulation Z’s conflict of…