Manage your "Third Party Arrangements" - QC your AMC
Lenders using AMC/VMCs for appraisal operations are being quizzed by examiners concerning their management of “Third Party Arrangements”.
As with all regulations, there is often a delay between the effective date of a regulation and the time examiners might start looking for specific behaviors. In the case of the revised Interagency Guidelines relating to “Third Party Arrangements”, this has been true. We have reached the point that examiners are now looking into the policies, processes, and procedures related to managing these relationships.
Interestingly, we have heard that there is interest in verifying the lenders prescribed “remedial action” should they discover deficits in the Third Party’s operations.
Lenders using AIMS to issue appraisal reviews to their trusted appraiser advisors are able to demonstrate clear and active QC activities to examiners. Additionally, the QC findings are helpful internally to help ensure efficiency within loan production operations.
For those instances where remedial action is required, lenders with AIMS in place can instantly regain business controls of appraisal operations, and instantly cutover to use AIMS for all appraisals. This safety net can bridge a transition to a different AMC/VMC; or it may be sustained as the preferred go forward approach to appraisal operations.
Here is an excerpt from the Interagency Gudelines: http://www.aimsdashboard.com/sites/default/files/file/IAEG%20-%20Third%20Party%20Arangements.pdf
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