There are two options for Federal Compliance.
Order appraisals and evaluations through an appraisal management company (AMC) like SAMCO Appraisal Management Company, with the AMC fee being passed on to the borrower.
Create an in-house appraisal/evaluation management and review department at your expense. It's not just separating the appraisal/evaluation ordering from the loan production staff, it's also reviewing the appraisal and evaluation to ensure it meets USPAP and Appraisal Standards.
Why use an Appraisal Management Company (AMC) before the Interagency Appraisal Guidelines (IAG)?
There were several good reasons why banks used appraisal management companies prior to The Interagency Appraisal and Evaluation Guidelines (usually national and larger regional banks):
- Greatly reduces the opportunity for fraud between lenders, sales people, and the appraiser, thus reducing losses due to overvalued security.
- But the major reason, it saves the bank money!
- Banks cannot compete with the efficiencies that an appraisal management company offers.
- The appraisal management company fee is part of the appraisal fee and is passed on to consumers at closing, not to the bank.
- RESPA - It's very difficult to define and recover the cost of an in-house management department as a closing expense that is compliant with RESPA. In-house costs are at the bank's expense, directly affecting your bottom line profit.
- Frees community bank/credit union management and staff for other more productive responsibilities.
- Most appraisal management companies have stringent quality control programs that increase the overall quality of the appraisal report.