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Should a regulated institution comply with the independence requirements if an appraisal is not required by the agencies appraisal regulations?

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Should a regulated institution comply with the independence requirements if an appraisal is not required by the agencies appraisal regulations?

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A regulated institution should ensure independence in the ordering process for an appraisal even if the appraisal was not required under the agencies’ appraisal regulations. Regulated institutions should also maintain independence for evaluations. 25. Does a tax-assessment value from the local taxing authority constitute an evaluation? Can a loan officer who approves and/or recommends a loan conduct an evaluation if the market value that the officer develops in the evaluation does not exceed the tax-assessment value? Answer: A value from the taxing authority alone is insufficient to be considered an evaluation. An evaluation report should include calculations, supporting assumptions, and, if utilized, a discussion of comparable sales. If tax assessment information is used as part of an evaluation, the regulated institution should document the facts and analysis used to demonstrate that there is a valid correlation between the assessed values of the taxing authority and the property’s m

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