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Old 11-03-2011, 12:29 PM
Socrates Socrates is offline
 
Join Date: Feb 2006
State: California
Professional Status: Certified Residential Appraiser
Posts: 347
Default Broker/Appraiser Familial Relationship

Can anyone direct me to the specific regulation, guideline, directive etc that would offer some guidance as to whether or not a familial relationship between an appraiser and a loan officer can exist on the same loan.

Is there some sort of regulation regarding the disclosure of the relationship? Can it exist? Can a family member of the production person (loan officer, processor etc) produce the appraisal? I need to provide concrete, factual regulations that provide that information.

This question was asked of me today and while I am aware that loan officers et al are not permitted in the appraisal selection process, somehow this LO's family member completed an appraisal for one of the LO's loans.
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Old 11-03-2011, 05:09 PM
Terrel L. Shields's Avatar
Terrel L. Shields Terrel L. Shields is offline
 
Join Date: May 2002
Location: Springtown, AmeRica
State: Arkansas
Professional Status: Certified General Appraiser
Posts: 40,312
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I took assignments from a family member. The bank maintained a letter from the OCC saying only that I must disclose that I am related to a loan officer involved in the transaction and it had no impact upon my determination of value. I would suggest any appraiser who has a relative working at the bank you are appraising for should disclose that and request the lender solicit a letter similar to what I had for their files. In these times, as opposed to those (in the 90s) the view of the regulators may have changed. But OTOH, we had more contact then than now with the directed intermediary. So....what impact on your business would happen if you were an appraiser and your daughter married the bank president, or maybe a bank examiner???? or, heaven forbid, Ben Bernanke...disown her.

It is not illegal. USPAP invites you to disclose any
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