Full Appraiser Independence Policy

Full Appraiser Independence Policy

I.              PURPOSE AND CONTENTS

 

General

 

This section outlines the Appraiser Independence Requirements Policy of Stewart Valuation Services, LLC ("Stewart")

 

Topics included in this policy are:

 

Policy Description Section II

Acceptable Business Practices Section III

Unacceptable Business Practices Section IV

Policy Controls Section V

 

 

II.            POLICY DESCRIPTION

 

Ensuring Valuations Independence

 

It is Stewart's goal to comply with all valuations independence statutes, regulations, and guidelines, including but not limited to the Interagency Guidelines and the Agencies' appraisal regulations. To that end, our business policy is to ensure that customers do not contact valuations services providers, including appraisers and other real estate professionals, in an attempt to unduly influence the provider's independent judgment. Selection of, and assignment to providers is at the sole discretion of Stewart.

 

In addition, no Stewart associate - including, but not limited to, Appraisal Operations and Vendor Management - will have compensation based on the closing of a loan transaction related to any valuation on which he or she has performed valuation management functions.

 

III.           ACCEPTABLE BUSINESS PRACTICES

 

  1. Customers in the general course of business engage Stewart to provide valuation products. Customers may give to Stewart a list of approved providers. These providers may or may not be included in Stewart panel at the sole discretion of Stewart.

 

  1. A customer's approved providers are added to Stewart's appraisal panel only if they meet Stewart's qualifications and performance standards. Client-approved providers who meet Stewart's standards are given the same consideration in the selection process as the existing panel members.

 

  1. Customers may provide a list of providers they do not want Stewart to use in support of their orders. Stewart may comply but reserves the right to ask for documentation to substantiate the request.

 

  1. Customers may be requested to provide Stewart the level of complexity, sales price, or owner's estimate of value so that Stewart may assign the order to a provider with appropriate qualifications. Other than sales contract information that may be made available to the provider in the normal course of business, Stewart does not provide the owner's estimate of value, sales price, offering price, or any other value to the provider.

 

IV.          UNACCEPTABLE BUSINESS PRACTICES

 

  1. Stewart does not accept an order for valuation products from a customer that includes a request for a specific provider. If such an order is received, Stewart will cancel the order and notify the customer.

 

  1. Stewart does not provide the majority of orders to a customer's preferred business partners.

 

  1. Stewart does not honor customer requests to assign work from specified subdivisions or geographies to specific providers.

 

  1. Stewart does not provide order activity reporting to customers at the provider level, preferred or otherwise. This includes notifying customers, for a given order, that a preferred provider was not used.

 

  1. Stewart does not allow customers to exclude all non-preferred providers from supporting their business, with the exception of providers the customer has placed on an exclusionary list.

 

  1. Stewart does not communicate predetermined, expected, or qualifying estimates of value; loan amounts; or target loan-to-value ratios to an appraiser or person performing evaluations.

 

  1. Stewart does not specify a minimum value requirement for the property that is needed to approve the loan or as a condition of ordering the valuation.

 

  1. Stewart does not imply that current or future retention of a person's services depends on the amount at which the appraiser or person performing an evaluation values a property.

 

  1. Stewart does not exclude a person from consideration for future engagement because a property's reported market value does not meet a specified threshold.

 

  1. Stewart does not use influencing tactics by withholding - or threatening to withhold - future business for an appraiser, or demoting or terminating - or threatening to demote or terminate - an appraiser. Such influencing tactics include, but are not limited to, artificially reducing an appraiser's score.

 

  1. Stewart does not request that an appraiser provide an estimated, predetermined, or desired valuation in an appraisal report prior to the completion of the appraisal report, or request that an appraiser provide estimated values or comparable sales at any time prior to the appraiser's completion of an appraisal report.

 

  1. Stewart does not provide 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 in order to influence or attempt to influence the development, reporting, result, or review of an appraisal.

 

  1. Stewart does not support any other customer request of business practice that could reasonably support lender pressure on valuations.

 

V.            POLICY CONTROLS

 

 

  1. Stewart reviews feedback received from providers through the appraisal influence hotline and reports material issues to Stewart sales/relationship managers.

 

  1. Stewart's personnel documents and reports instances of attempted influence as they occur in the normal course of business. Instances are summarized, reported and reviewed monthly by appraisal division management.

 

  1. Stewart maintains an appraisal influence hotline and email box exclusively for the use of reporting violations of appraiser independence. All calls and emails are investigated and the results are logged and reported to the appropriate client.

 

  1. Stewart's Quality Control group checks the appraisal report that the Appraiser's Certifications section of the appraisal report is signed, ensuring - among other items - that the appraiser has no present or prospective interest in the subject property, and no present or prospective interest or bias with respect to the participants in the transaction.