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USPAPMEDIUM18.2% of exam

An OCC-regulated bank makes a $180,000 residential real-estate loan relying on 12 CFR 34.43(a)(1), with no separate appraisal requirement or OCC demand for an appraisal. What valuation obligation remains?

Correct Answer

D) Obtain an appropriate evaluation of the real-property collateral

Under the stated OCC residential threshold exemption, an appropriate evaluation of real-property collateral remains required by 34.43(b). The threshold does not excuse separate applicable appraisal requirements or OCC safety-and-soundness authority. An evaluation is not automatically a licensed/certified appraisal.

Answer Options
A
Perform no collateral valuation of any kind for the loan
B
Require a certified appraisal, because the loan is $180,000
C
Treat the evaluation as a licensed appraisal under the rule
D
Obtain an appropriate evaluation of the real-property collateral

Why This Is the Correct Answer

Under the stated OCC residential threshold exemption, an appropriate evaluation of real-property collateral remains required by 34.43(b). The threshold does not excuse separate applicable appraisal requirements or OCC safety-and-soundness authority. An evaluation is not automatically a licensed/certified appraisal.

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