[dcsluder1]

I know this has been asked before but I’m trying to understand what is acceptable. We have a client who started a loan with another FI. The loan officer he used moved to our bank. The client has followed him and has requested us refinance the loan he had at the other bank. The client didn’t really want to pay for another appraisal, $2,500.00, when the appraisal was done in January, 2019 not 4 months old. Our client contacted his previous bank and they were agreeable to send a letter to the appraiser to have the appraisal transferred to us. We also have an engagement letter asking for the appraisal to be transferred to us. In the letter we have stated the appraisal performed for Bank 123 be transferred to us. The appraiser charged the client a $200.00 fee for transferring to my bank. Everything I read says “appraisals that have been readdressed or altered by the appraiser with the intent to conceal that the original client”. I’m just trying to make sure we are good. Can anyone help?

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[ecollinsworth]

Good afternoon!
When requesting to use an appraisal from another bank, you should not involve the appraiser. The bank that has the appraisal simply sends the report to the bank requesting it and the appraiser does not need to be involved. If you are requesting the report, then ask the other bank to send you a copy of their actual report (your FI’s name does not need to be in the report), they need to attach a copy of their engagement letter proving they ordered the report properly (and that the appraiser has no interest in the transaction, parties or the property) and the report should be reviewed by your FI to confirm it meets your bank’s policies. By asking the appraiser to “readdress” the report over to you (or if you had asked yourself), that bank has potentially violated regulatory guidelines AND by the appraiser agreeing to do so, they have potentially violated USPAP! There is no need to ever involve the appraiser for this process. IF you want to get the appraiser involved (and this would be my suggestion), ENGAGE the appraiser as a whole new assignment and let him/her know you know they just completed it for another institution recently. Let them know when you engage them you expect the effective date to be on or after the date you engage them and you expect they might charge a small fee as they would need to re-inspect the property. Then, if you have ANY problems with the report, you can go back to the appraiser for corrections (you can’t do that when you use a report written for another institution)!

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