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February 20, 2008


Cedric, Prince of Compliance

On reading your February 22nd blog entry concerning the review of appraisals (NCUA Legal Opinion Letter 08-012) I pulled out the referenced FFIEC guidance and decided some compliance due diligence was appropriate. The FFIEC Q & A reads in part:

19. Should all appraisals undergo a compliance review?
Answer: Yes, prior to a final credit decision, regulated institutions should perform a compliance review on all appraisals to confirm that they comply with the minimum appraisal standards as outlined in the agencies’ appraisal regulations, the interagency guidelines, and the independence statement. Loan administration files should document this compliance review, which may be in checklist or narrative format.

Given the above, I thought it prudent to confirm that we review all appraisals and that we could document the review. For our risk profile, insuring that our procedures reflected the requirement to perform and the content of an appraisal review, coupled with the reviewer initialing the front page of the appraisal, seems sufficient. This practice, though not a checklist or a narrative, seems supported by the legal opinion letter and compliant with FFIEC guidance.
~ Cedric, Prince of Compliance

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