Who should be considered the “loan production staff” for purposes of achieving appraiser independence?
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. Employees responsible for the credit administration function or credit risk management are not considered loan production staff.” Are processors, closers, secondary marketing employees, underwriters, etc. permitted to order appraisals if they do not receive commission or incentives to close loans, but they ultimately report up to a senior-level employee who is responsible for loan production? The Code states that members of the lender’s loan production staff who are compensated on a commission basis or who report to any officer of the lender not independent of the loan production
Related Questions
- Who should be considered the loan production staff for purposes of achieving appraiser independence? Could loan production staff select an appraiser?
- Who should be considered the "loan production staff" for purposes of achieving appraiser independence?
- Who should be considered the "loan production staff" for purposes of achieving appraiser independence?
