Compliance & Guidelines
Appraisers First Inc. adheres to the appraisal independence requirements/guidelines as established by the Dodd-Frank Act, Fannie Mae, Freddie Mac and the Department of Housing and Urban Development (HUD).
Appraisers First Inc. believes in building lasting relationships with clients based on mutual trust. All appraisers engaged by Appraisers First Inc. are at a minimum, licensed or certified by the state in which the property to be appraised is located.
No employee, director, officer or agent of Appraisers First Inc. shall influence or attempt to influence the development, reporting, result or review of an appraisal through coercion, extortion, collusion, compensation, inducement, intimidation, bribery or any other manner including but not limited to:
1. Withholding or threatening to withhold timely payment or partial payment for an appraisal report
2. Withholding or threatening to withhold future business from an appraiser, or demoting or terminating or threatening to demote or terminate an appraiser
3. Expressly or impliedly promising future business, promotions, or increased compensation for an appraiser
4. Conditioning the ordering of an appraisal report or the payment of an appraisal fee or salary or bonus on the opinion, conclusion or valuation to be reached or on a preliminary value estimate requested from an appraiser
5. Requesting that an appraiser provide an estimated, predetermined, or desired valuation in an appraisal report prior to the completion of the appraisal report or requesting that an appraiser provide estimated values or comparable sales at any time prior to the appraiser’s completion of the appraisal report
6. Providing to an appraiser any anticipated, estimated, encouraged, or desired value for a subject property or a proposed or target amount to be loaned to the borrower except that a copy of the sales contract for purchase transactions may be provided
7. Providing to an appraiser, appraisal company, appraisal management company, or any entity or person related to the appraiser, appraisal company, or appraisal management company, stock or other financial or non-financial benefits
8. Removing an appraiser from the list of qualified appraisers, or adding an appraiser to an exclusionary list of disapproved appraisers, in the connection with the influencing or attempting to influence an appraisal as described above (this prohibition does not preclude the management of appraiser lists for bona fide administrative or quality-control reasons based on written policy); or
9. Any other act or practice that impairs or attempts to impair an appraiser’s independence, objectivity, impartiality or violates law or regulation including but not limited to the Truth In Lending Act (TILA) and regulation Z or the USPAP
Nothing in this section shall be construed as prohibiting Appraisers First Appraisal Management (or the lender) from requesting that an appraiser (i) provide additional information or explanation about the basis for a valuation, or (ii) correct objective factual errors in an appraisal report.
How Did the Dodd-Frank Act Impact Compliance?
Following the Great Recession, the 2010 Interagency Appraisal & Evaluation Guidelines (AIG) were introduced to reestablish the separation between the appraisal order management process and the loan production process. These regulations also drew specific attention to the importance of an appraisal review process.
The necessity of appraisal companies expanded following the Dodd-Frank Act, signed into law in 2010. This especially applies to community bankers who were by and large unfamiliar with appraisal management companies (AMCs) as a whole.
Along with the Federal Reserve Interim Final Rule, the Dodd-Frank Act also established a Consumer Complaint Hotline and a standard “customary and reasonable” appraisal fee to pay local appraisers. These laws made the community lender responsible if the appraisal management companies did not comply.
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