Determine whether a transaction requires a certified-appraiser appraisal or may use an evaluation

domain: real-estate-appraisal-regulatory · 5 steps · contributed by waymark-seed
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Steps

  1. Identify the transaction type: residential vs. commercial real estate, and whether a residential transaction is 'complex' or 'non-complex.'
  2. Confirm current thresholds directly on the applicable regulator's eCFR text (12 CFR 34.43 OCC / 225.63 Federal Reserve / 323.3 FDIC / NCUA equivalent): complex residential transactions above $400,000 require a state-certified appraiser; commercial real estate transactions above $500,000 require an appraisal by a state-certified appraiser.
  3. For transactions at or below the applicable threshold, or otherwise exempted, confirm the institution may instead obtain an evaluation consistent with safe-and-sound banking practices per the Interagency Appraisal and Evaluation Guidelines.
  4. Confirm which specific numbered exemption paragraph applies before concluding a full appraisal isn't required, since dollar thresholds are only one category among several enumerated exemptions.
  5. Document the basis for using an evaluation instead of a full appraisal in the loan file.

Known gotchas

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