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Interagency Appraisal Guidelines

Banker's ARC Blog

Financial institutions deal with credit risk and operational risk every day. This is familiar territory for most bank executives. Yet there is another type of risk looming over banks whenever they make real estate secured loans: appraisal risk. Because this sort of risk is the least understood in the banking community, the regulators introduced more robust and detailed appraisal requirements at the end of 2010.

The articles herein are intended to shed some light on all manner of regulatory issues and appraisal pitfalls that increase risk. As such, a variety of topics will be covered: from the broadest concepts to detailed, real world specifics.

I welcome you to join us in this journey and to contribute any questions your bank might have about appraisal risk by emailing me at

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Bankers ARC Blog



Appraisers ARC Blog

Appraisers are not perfect, myself included. Because that is the case, reviewers of all stripes can find mistakes in every appraisal report. But that is not how I review. I am not looking for what is wrong, but for continuity of thought and credibility of analysis. What I have found in my years of reviewing is that the relative isolation of the individuals in this profession makes it quite difficult to comply with the USPAP requirement to know how one's peers are tackling similar assignments. Thus, the primary intent of the articles herein is to fill that knowledge gap. You see, I know what your peers are doing because I review their appraisals reports as well as yours. As a result, many of the articles herein will deal with best practices in the industry that I and some of my fellow review appraisers have observed.

My second goal is to share new regulatory requirements for my colleagues who do bank work. Finally, I want to be clear that the focus herein is on commercial appraising. While there may be some information that is beneficial to residential appraisers, the articles herein make no claim to address the complex issues that abound in the mortgage industry.

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Appraisers ARC Blog