July 1, 2014 at 4:11 pm EDT #6019kmeadeParticipant
I have been asked a question. Can we give the buyer’s realtor the contact information for the appraiser? Since it is the buyer’s realtor I don’t see a need for the realtor to need the information. If it was the selling realtor and the realtor was the only way the appraiser can gain access to the property I can see a need, but not when the buyer’s realtor just want to contact the appraiser. Please give me your thoughts on this situation.July 2, 2014 at 12:06 am EDT #6020rcooperMember
This is definitely a grey area as I know of nothing that would technically prohibit it. However, you need to be careful that your actions don’t violate the valuation independence requirements, specifically coercion, in Reg Z as well as the valuation independence rules in the Interagency Guidelines.
1026.42(c)(1)(A) states: (i)
Examples of actions that violate paragraph (c)(1) include:
(A) Seeking to influence a person that prepares a valuation to report a minimum or maximum value for the consumer’s principal dwelling.
My concern would be that a practice of giving contact information to the buyer’s realtor could be deemed an indirect way of influencing the outcome of the appraisal.
We’ll see if Jack has any additional information.July 2, 2014 at 8:57 am EDT #6021jholzknechtKeymaster
There is a fine line between coercion and providing reasonable assistance to the appraiser. The Dodd‐Frank Act states: The requirements of subsection (b) shall not be construed as prohibiting a mortgage lender, mortgage broker, mortgage banker, real estate broker, appraisal management company, employee of an appraisal management company, consumer, or any other person with an interest in a real estate transaction from asking an appraiser to undertake 1 or more of the following:
(1) Consider additional, appropriate property information, including the consideration of additional comparable properties to make or support an appraisal.
(2) Provide further detail, substantiation, or explanation for the appraiser’s value conclusion.
(3) Correct errors in the appraisal report.
The buyer’s agent might be inclined to try to reduce the value in order to get a lower sales price. The seller’s agent might want the opposite result. The seller’s agent presumably has the most information about the property.
There is nothing that requires or prohibits you from sharing appraiser contact information from either agent. You should adopt a policy on this matter with only limited exceptions to the policy. You may inquire why the agent needs to contact the appraiser.
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