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Ownership of an appraisal management company

Zoe

Elite Member
Joined
Sep 15, 2020
Professional Status
Certified General Appraiser
State
Tennessee
Can a lender have part ownership of an appraisal management company?
 
Do you see a conflict of interest to the borrower?
Does not matter what you or I see. Banking laws are written to allow this as long as there is a separation between the loan officers and the appraisal department or the AMC. This is the way it is and will remain as long as the banking lobby keeps paying Congress.
 
Does not matter what you or I see. Banking laws are written to allow this as long as there is a separation between the loan officers and the appraisal department or the AMC. This is the way it is and will remain as long as the banking lobby keeps paying Congress.
I have one AMC which deals with this same lender all the time. I think the AMC is part of that lender. AMC should disclose this to everybody.
 
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Can a lender have part ownership of an appraisal management company?
Yes. Wells Fargo owns.. or used to anyway.. part of Rels and handled most of Wells Fargos appraisal requests. The rule has never been that Banks could not order appraisals in house. The rule was that there needed to be a firewall between the loan officer and the appraiser.
 
That is right. You cannot talk to anyone involved, loan officer, who is getting paid for getting the loan. Everyone else at the lenders you can talk to, but many AMC people are to stupid to know that.
We are not adults and cannot talk to, and be evilly influenced, by a loan officer. And this thought destroyed appraising when hvcc was invented.
 
Does not matter what you or I see. Banking laws are written to allow this as long as there is a separation between the loan officers and the appraisal department or the AMC. This is the way it is and will remain as long as the banking lobby keeps paying Congress.
That doesn't matter in the banking regs. The person over the loan review department and appraisers in the bank can report directly to the board of directors, therefore bypassing any internal influence from loan officers inside the bank. If the loan officer has a problem, they have to go through the board of directors to resolve their issue. Most likely a loan officer might be on the board of directors, but many on the board of directors are not loan officers. Many are lawyers, etc.etc.etc.
 
There is nothing wrong with a loan officer asking an internal staff appraiser to explain an issue or the loan review officer.

That is not against any banking regulations. When the auditors come in they will do the same thing to the loan officers and the compliance side (loan review) of the bank. The auditors will do it formally and want a response formally. That goes directly to the board of directors.
 
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