Fannie Mae Appraiser Independence Requirements
SettlementOne's compliance department actively monitors newly released regulations affecting banking institutions and credit unions, such as Fannie Mae Appraisal Independence Requirements.
Differences between HVCC and Fannie Mae Appraisal Independence Requirements
Removal of Appraisal from Panel
- Required prior written notice including written evidence of appraisers' misconduct, etc.
- Removal could only be based off of quality or performance issues
- Does not require written notice
- Only specify can not be removed for influencing an appraisal (i.e. not value related)*
- *Some states have already passed and published rules that are similar to HVCC that negate the changes above and place additional requirements on a lender, so it's always important to be familiar with the requirements of each state a lender services.
Delivery of Appraisal to Borrower
- Specifies 3 days prior to closing, unless borrowers waive right but does not address the difference between the original appraisal and one with revisions
- In the case of revisions it may be provided at closing as long as the revision had no impact on the value
Appraiser Selection
Fannie Mae: "Any employee of the Seller (or if the Seller retains an appraisal company or appraisal management company, any employee of that company) tasked with selecting appraisers for an approved panel or substantive appraisal review must be: Appropriately trained and qualified in the area of real estate appraisals; and in the case of an employee of the Seller wholly independent of the production staff and process"
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