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Appraisal on Bank Owned Property (OREO)

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  • #5626
    Bellisima
    Participant

    Would providing the borrower/purchaser with a copy of the banks “acquisition appraisal” at time of foreclosure satisfy the new appraisal regulations under REG B and HPML? I would think not, but need some guidance.

    #5640
    Bellisima
    Participant

    Following up requesting a response on 3/19 post. Please advise.

    Thank you.

    #6428
    rcooper
    Keymaster

    I apologize we missed your question. I’m sure you found your answer, but I believe you are correct – IMO the acquisition appraisal would not satisfy the HPML “flip” appraisal requirement. There isn’t a requirement in Reg B to perform an appraisal, but there are delivery requirements for appraisals and valuations.

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