Appraisers Ordering - Appraiser Independence Rules
There appears to be some confusion about the distinction between the Appraiser Independence Policy (AIR) and the Appraisal Ordering Process. The AIR policy is designed to ensure non-interference in the appraisal process, including removing originator staff from any conversations or interactions with appraisers and delegating communication only to non-production staff, such as processors or underwriters.
It sets forth how to create an independent appraiser roster and an appraisal approval process. In the absence of appraiser rosters, we may use an Appraisal Management Service (AMC) that rotates and independently assigns appraisers, thereby ensuring independence and eliminating the need to maintain a roster.
Small Companies may not have the roles referenced in the rules or plan
We do not have an appraiser roster, so we use an AMC. Origination staff do not order appraisals either directly or through an AMC. Only processors may order appraisals through the AMC, and they do not select individual appraisers, but assign them through their rotation. If we do not have an underwriter, per se, we will remove reference, but the role of processing does include an underwriting-type review, so really these two roles overlap.
