I. PROHIBITION OF MORTGAGE BROKERS & COMMISSION BASED LENDER STAFF
Mortgage Brokers or any member of a lenders staff who are compensated on a commission basis
tied to the successful completion of a loan are prohibited from selecting, retaining or compensating
an FHA Roster
Appraiser in any manner
II. APPRAISER SELECTION IN FHA CONNECTION
The lender is responsible for assuring the appraiser who actually conducted the appraisal is correctly identified
in FHA Connection - subject to administrative sanctions for failure to do so.
III. THIRD PARTY FEES
The lender must ensure:
- Appraisers are not prohibited from recording the fee the appraiser was paid on the appraisal in the report
- FHA Roster appraisers are compensated at customary & reasonable rates for the services performed
- Lender may not include a fee for appraisal management process
- Any management fee charged by an AMC or 3rd party must be for actual services (ordering, processing, review)
- AMC or 3rd party fee may not exceed what is customary and reasonable
IV. PREVENTION OF IMPROPER APPRAISER INFLUENCE:
None of the following may have substantive communications relating to or impacting the valuation, including
ordering or managing an appraisal assignment:
- Members of the loan production staff
- Any person who is compensated on a commission basis upon successful loan completion
- Any person who reports, ultimately, to any officer of lender not independent of the loan production staff
- DE Underwriters responsible for appraisal quality may request clarifications and discuss appraisal
quality components
- If absolute lines of independence cannot be achieved as a result of the lenders limited size and staff,
the lender must be able to demonstrate that it has prudent safeguards to isolate its collateral evaluation
process from influence or interference
>> FHA COMPLIANCE - PAGE 2
HVCC COMPLIANCE