CRE Appraisals: Regulations and the Review Process

For at least 25 years, bankers have worked under multiple sets of rules and guidelines concerning the ordering and reviewing of appraisals. Appraisers have worked under the Uniform Standards of Appraisal Practice (USPAP) for even longer. This program provides a concise overview of the various rules and guidelines, plus key nuances that have created differences among the approaches taken by banks and endorsed or supported by their regulators. Because they are guidelines, not regulations with absolute deadlines, there is discretion in how regulators apply various features. Do you know the key factors that drive the discretion? What are some tips and traps in handling review outcomes? Can your bank have different levels or types of reviews for commercial properties? What key factors drive how to set the different levels?

Highlights

  • Overview of guidelines and issues critical to CRE appraisals
    • The five minimum standards and what they really mean, as derived from the original 14 points in the Financial Institutions Reform and Recovery Act of 1989 (FIRREA) Title XI that govern how banks order and use appraisals
    • What is FIRREA? (and other regulatory guidelines still in place)
    • Yes, you can use appraisals prepared for other banks
  • Types of reviews, as suggested by the guidelines
    • Administrative/compliance review plus a sample checklist
    • Technical/internal review plus a sample checklist
    • Outside/third party review plus sample comments
    • Ideas for setting dollar limits
    • Ideas for screening for Uniform Standards of Appraisal Practice (USPAP) as of Jan. 1, 2020
    • Why your bank should create an appraisal/CRE properties database
  • What about evaluations?
    • Not just for loans below the dollar thresholds
    • New (as of 2010) evaluator independence guideline
  • Appraisal review outcomes and when to request revisions

Who Should Attend?

CRE lenders, commercial lenders, private bankers, small business lenders, credit analysts, portfolio managers, assistant relationship managers, consumer and mortgage lenders, loan review specialists, special assets officers, lending managers, credit officers and CRE support personnel.

"Informative Class with a great speaker." -- Jill Tetrault, Kennebunk Savings Bank

"Very useful information to allow the Bank to update appraisal review process and procedures to be more risk based." -- Beverly Fortner, Texas Champion Bank