Due to the Interagency Appraisal Guideline requirements, regulators are beefing up their examination of each bank's appraisal program.
How do your bank appraisal guidelines stack up on Interagency Appraisal Guideline issues?
Has your bank re-examined its appraisal policy, procedures, and processes since Interagency Appraisal Guidelines were issued?
Have in-house personnel handling appraisal issues been trained to bid, engage, and review appraisal reports?
How are you handling renewing credits, with evaluations or new appraisals?
How is your bank determining that the appraisers who are bid and selected have the requisite expertise and education to competently complete specific appraisal assignments?
Are you examining credit and collateral risk to determine when to outsource appraisal reviews?
If you use an AMC, how did you select that firm and what measures are you taking to audit their processes and reviews?
Is there sufficient separation between your loan production and appraisal ordering staff?
Is your evaluation staff sufficiently trained?
Do you have a program in place to monitor market trends and address asset quality issues?
