OCC bulletin regarding AMCs, lenders, and Appraisal Advisor
On October 30, the OCC issued a bulletin to all national banks and savings associations entitled “Third-Party Relationships: Risk Management Guidance.” The bulletin, in a nutshell, outlines how lenders should manage and ensure compliance of their third party vendors. AMCs, third parties in the OCC bulletin, must be managed by specific guidelines in order for lenders to maintain compliance.
Appraisal Advisor offers compliance with that regulation by providing lenders, AMCs, and appraisers with its ratings and reviews system. Appraisers’ constant scoring of AMCs on Appraisal Advisor is now, more than ever, THE key deciding factor in which AMCs lenders use. With Appraisal Advisor, Appraisers are being heard, AMCs are being scored, and lenders have an easy, cost-effective way to abide by the OCC mandate.
The bulletin requires that lenders now maintain a compliance solution for AMCs that continually monitors the third party, know the third party’s business experiences and reputation, and also know the business’s financial condition (among other things).
Appraisal Advisor is the best (and only) solution out there for lenders to get this sort of compliance. Appraisers review the AMCs they’re working with after every order they submit to the AMC, giving lenders continual monitoring and knowledge of the AMC’s business reputation. Appraisal Advisor also allows lenders to get the AMC’s financial history when dealing with the AMC’s own third parties, so lenders and appraisers both can know exactly how financially sound their AMCs are.
It’s more important than ever for 1) appraisers to post reviews after every order they complete, because lenders are (and now they HAVE to) listen to what appraisers are saying about AMCs, 2) AMCs to close every order requesting for an appraiser to review their company, so that they can show lenders all of the ways their company is already complying with the new OCC guidelines, and 3) lenders to use Appraisal Advisor to stay on top of the reputation of current and potential clients.
With the OCC’s bulletin, the compliance road now officially goes through Appraisal Advisor.
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I know it’s a dreamers idealist statement, but; / If lenders were not backed by taxpayer funds, they would be paying a lot more attention to risk management. Bail outs and bail ins. Neither is an effective solution compared to loan originators holding the interest and liability for that loan, for the life of the loan. I’ve become numb to this never ending stream of guidance documents that fails to address the root cause of the problems.
Appraisal Advisor is a worthy market participator, and it would be nice to see more appraisers participating in client grading.