Third Party Oversight Compliance & Best practices

www.Nationwide – Appraisal.com

888-760-8899

Jennifer Graham

[email protected]

888-760-8899 x211

appraiser independence

What’s on the agenda?

appraiser selection

appraisal disputes

engagement letters

Director of Quality

Assurance

& Compliance

Cristy Conolly Kevin Johnson

Business Development

Quick Poll

Who’s with us today?

NAN Compliance Portal

Main Objectives

Challenge: Managing the risk involved in the appraisal process.

Goal: A better understanding of the regulatory requirements and best practices.

Get some clarity and relief: from the burden of the unknown.

Which is better?

Managing in-house?

Outsourcing to an AMC?

OR

Managing In-House?

Policies to promote an effective program

System to document & monitor compliance

System to monitor appraiser performance

Staff expertise to ensure QC

Ability to manage vendors

Best Practices for Managing In-House

Put systems in place

Keep staff separate from loan production

Clearly written policies

Consistency and transparency

Outsourcing to an AMC?

Conduct thorough due diligence with service provider

Access to policies, procedures, controls & training materials

Clear contract in place

On-going monitoring for compliance

Continuous oversight for 3rd party

Best Practices for outsourcing to an AMC

Contract in place

Transparency from service provider

What should my contract say?

Legal & regulatory compliance

Selection of appraisers

Payment of appraisers

Representations & warranties

Insurance coverage with AMC

Managing Regulations:

Dodd-Frank

InterAgency Evaluation Guidelines

On-going State Statutes and Rules

FIRREA

TILA

ECOA

USPAP

NAN Compliance

Compliance Task Force

Compliance Manual

Compliance Portal

Be Consistent, clear, and transparent

Quick Poll

Appraiser Independence

• Requirement

• Independence

• No Interest

• Misrepresentation

• Best Practices

• Ordering, assigning and reviewing of appraisals separate from loan process

• Manage proper communication

• Regular staff training

• At NAN…

Appraiser Selection

• Requirement

• Education, expertise, experience, data access, & certification

• Periodic appraisal review

• Unbiased opinion

• No interest in property

• No involvement from loan production

• Best Practices

• Thorough vetting process

• Geographic competency and experience

• Complex and unique assignments

• Performance monitoring system

• Document & be consistent with the policy

• At NAN…

So what about?

Approved appraiser lists

Exclusionary lists

Background checks

Customary & reasonable fees

Feb 5th @ 2pm EST.

Appraisal Disputes

• Formal Appeals Process

• Transparent Documentation

• Timely Responsiveness

• Appraiser Independence

• Stick to the Facts

• Certified Appraiser on staff

• Professionalism

Appraisal Dispute Form

Quick Poll

Engagement Letters

• Communication

• Document Expectations

• USPAP Compliance

• Retain copies; be consistent

Kevin Johnson

kjohnson@nationwide-

appraisal.com

813-749-8856 - direct

Cristy Conolly

cconolly@nationwide-

appraisal.com

813-749-8842 - direct

ATTEND Compliance Webinar Part II.

February 5th - 2pm EST

Click here to register: