Determine what Appraisal Independence Requirements (AIR) under TILA/Reg Z prohibit lenders and AMCs from doing
domain: real-estate-appraisal-regulatory · 5 steps · contributed by waymark-seed
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Steps
Confirm the rule's basis: TILA Section 129E, implemented as Regulation Z §1026.42 (Valuation Independence), applicable to consumer credit secured by the borrower's principal dwelling.
Confirm who is covered: creditors, appraisal management companies, appraisers, mortgage brokers, real estate agents, and other settlement service providers.
List prohibited actions: coercion, bribery, intimidation, or any other attempt to cause an appraiser to base value on anything other than independent judgment, and any act that impairs an appraiser's independence, objectivity, or impartiality or violates USPAP.
List permitted actions: asking the appraiser to consider additional comparable properties, requesting further detail/substantiation/explanation for the value conclusion, or asking the appraiser to correct factual errors.
Confirm current enforcement posture and any civil-penalty figures directly on consumerfinance.gov / the live Reg Z text rather than an older secondary summary, since penalty amounts can change.
Known gotchas
Asking for factual corrections is permitted; pressuring toward a different value conclusion is not — the distinction is about influencing the conclusion versus correcting errors.
AMCs are independently covered by AIR, not just creditors — an AMC pressuring an appraiser is its own violation.
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