What do the rules require a lender to review in a CRE appraisal?
The OCC's appraisal rule, 12 CFR 34 Subpart C says appraisals for federally related transactions shall "Be written and contain sufficient information and analysis to support the institution's decision to engage in the transaction" and shall "Analyze and report appropriate deductions and discounts for proposed construction or renovation, partially leased buildings, non-market lease terms, and tract developments with unsold units."
The 2010 Interagency Appraisal and Evaluation Guidelines set the timing and the purpose of the review: "As part of the credit approval process and prior to a final credit decision, an institution should review appraisals and evaluations to ensure that they comply with the Agencies' appraisal regulations and are consistent with supervisory guidance and its own internal policies." Through that review, the institution "should be able to assess the reasonableness of the appraisal or evaluation, including whether the valuation methods, assumptions, and data sources are appropriate and well-supported."
In practice that means three questions for every report. Did the appraiser answer the assignment the lender gave? Does the math in the report hold together? And do the report's assumptions agree with the rent roll, operating statements and budget already in the credit file?
How does ValueCheck review an appraisal?
ValueCheck runs on the MightyBot platform. Your appraisal review policy is written in plain English, with a depth of review for each risk tier and property type. The agent reads the appraisal report, the engagement letter and the loan file together.
It first tests the assignment: the intended user and use, the value premises requested, the effective date, and who engaged the appraiser. Then it recomputes the report. Net operating income is rebuilt from the appraiser's own income and expense lines, the capitalization rate is applied again, and the indicated value is compared with the value the report concludes. The comparable sales grid is checked for sale dates, distance and the size of gross and net adjustments.
Finally it ties the appraisal to the file. Occupancy, in-place rent and expenses are compared with the rent roll and trailing operating statement the underwriter used, and the extraordinary assumptions and hypothetical conditions are listed so the reviewer sees what the value depends on. The output is a review memo with each flag cited to a report page. A qualified reviewer at your institution accepts the appraisal or sends questions back.
What should the review say about independence, value premises and documentation?
Independence is a rule, not a preference. Under 12 CFR 34.45, a fee appraiser "shall be engaged directly by the regulated institution or its agent, and have no direct or indirect interest, financial or otherwise, in the property or the transaction." A review should confirm who ordered the report before it looks at the number.
Construction and value-add loans need the right value for the loan. The guidelines say an institution financing construction or renovation "would generally request an appraiser to provide the property's current market value in its 'as is' condition, and, as applicable, its prospective market value upon completion and/or prospective market value upon stabilization," and that it "should consider the prospective market value that corresponds to the credit decision and the phase of the project being funded."
The review itself has to leave a record. The guidelines say documentation "should describe the resolution of any appraisal or evaluation deficiencies, including reasons for obtaining and relying on a second appraisal or evaluation," and "should provide an audit trail that documents the resolution of noted deficiencies." ValueCheck keeps each flag, the reviewer's response and the resolution together in the credit file.