Due Diligence and Ongoing Monitoring

  • 1.  Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    This message was posted by a user wishing to remain anonymous
    Posted 08-31-2021 12:04 PM
    This message was posted by a user wishing to remain anonymous

    We have just recently written our TPRM policy which includes a section for vendors that are scoped out of our Program. In that list we included appraisers, as I was under the impression that there wasn't much on-going monitoring that could be done and I've never turned up much information on what type of review and on-going monitoring would be especially beneficial when I've tried to research in the past, but now our audit group is pushing back some and asking why we wouldn't consider an appraiser organization to be a key relationship. 

    If you scope appraisers out of your program, can you tell me why? Also, for further context, I do work for an insurance company.


  • 2.  RE: Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    This message was posted by a user wishing to remain anonymous
    Posted 08-31-2021 12:16 PM
    This message was posted by a user wishing to remain anonymous

    We scope individual appraisers out, but conduct due diligence on AMC's where we felt the risk was higher.


  • 3.  RE: Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    This message was posted by a user wishing to remain anonymous
    Posted 09-01-2021 08:43 AM
    This message was posted by a user wishing to remain anonymous

    What type of due diligence are you conducting? Thanks!


  • 4.  RE: Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    This message was posted by a user wishing to remain anonymous
    Posted 09-01-2021 12:08 PM
    This message was posted by a user wishing to remain anonymous

    TPRM doesn't do any due diligence on Appraisers. We outline in our policy what/who is excluded and note the due diligence the responsible units/department performs.


  • 5.  RE: Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    This message was posted by a user wishing to remain anonymous
    Posted 08-31-2021 01:31 PM
    This message was posted by a user wishing to remain anonymous

    ​As a bank, we scope out appraisers for various reasons: (1) they are vetted and approved by our Appraisal department, (2) their work and work product is monitored, reviewed and scored by our Appraisal department, (3) they are registered, licensed and subject to governmental scrutiny, (4) they have limited access to PPI (eg only the borrowers applying for the loan), (5) they are subject to corporate requirements for the Appraisal Company employing them, (6) their service is transaction (no guarantee they will get more business from us), etc.


  • 6.  RE: Appraisers/Appraisal Companies - Why are they scoped out of monitoring?

    Posted 09-03-2021 11:41 AM
    We scope in appraisers but risk rate them low based on the volume of NPPI that they have access to.  Prior to onboarding a new appraiser we require the following due diligence:
    • copy of license
    • COI
    • basic data base investigation.
    Once onboarded, we do not subject appraisers to ongoing due diligence reviews other than ongoing OFAC.

    Shelly

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    Shelly Chase
    Senior Risk Analyst Officer
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