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Who should be considered the “loan production staff” for purposes of achieving appraiser independence?

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Who should be considered the “loan production staff” for purposes of achieving appraiser independence?

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The term “loan production staff” is not defined in the Code. However, the FAQs prepared by federal agencies on the agencies’ appraisal regulations specify as follows: “The loan production staff consists of those responsible for generating loan volume or approving loans, as well as their subordinates. This would include an employee whose compensation is based on loan volume or the closing of a loan transaction.

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