PURPOSE AND CONTENTS
This section outlines the Appraiser
Independence Requirements Policy of Stewart Valuation Services, LLC ("Stewart")
Topics included in this
Policy Description Section II
Acceptable Business Practices Section
Practices Section IV
Policy Controls Section
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
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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Stewart does not provide the majority of
orders to a customer's preferred business partners.
- Stewart does not honor customer requests
to assign work from specified subdivisions or geographies to specific
- 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.
- 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
- 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
- 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.
- 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.
- Stewart does not exclude a person from
consideration for future engagement because a property's reported market
value does not meet a specified threshold.
- 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.
- 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.
- 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.
- Stewart does not support any other
customer request of business practice that could reasonably support lender
pressure on valuations.
- Stewart reviews feedback received from
providers through the appraisal influence hotline and reports material
issues to Stewart sales/relationship managers.
- 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
- 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
- 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.