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Are all banks required to review every appraisal and evaluation?

My bank is a small community bank with limited compliance resources. Is the bank required to review every appraisal and evaluation under the interagency guidelines?

Yes. The appraisal review requirements are found under Section XV of the Interagency Appraisal and Evaluation Guidelines and are further clarified in FAQ #5 of the Frequently Asked Questions on the Appraisal Regulations and the Interagency Appraisal and Evaluation Guidelines which explains, “As part of the credit approval process and prior to making a final credit decision, a financial institution should review appraisals and evaluations to confirm that they comply with the agencies’ appraisal regulations and the financial institution’s internal policies.”

There are no exemptions based on the size of the bank. (December 2019)

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