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Ethics & Fraudmedium18% of exam

For a consumer loan secured by the borrower’s principal dwelling, a $520,000 purchase receives a $498,000 appraisal. Through the lender’s permitted channel, the originator submits three genuine, relevant comparable sales above $520,000 for consideration, without threats, incentives or a demand for a target value. Is this request itself prohibited by Regulation Z’s valuation-independence rule?

Correct Answer

C) Permitted: sending comparable sales through the proper channel is allowed

C. Submitting appropriate comparable information for consideration is permitted. The regulation expressly allows requests to consider additional appropriate property information. The appraiser remains responsible for evaluating relevance and the supported value; a higher-priced comparable does not guarantee a higher appraisal. Scope and exceptions: Other lender or investor procedures still apply. Permission to provide information is not permission to dictate the result. Source: 1026.42(a), (c)(3)(i)–(iii) — https://www.consumerfinance.gov/rules-policy/regulations/1026/42/

Answer Options
A
Prohibited: any contact at all with the appraiser about value is coercion here
B
Permitted only where the lender also raises the appraisal fee paid
C
Permitted: sending comparable sales through the proper channel is allowed
D
Prohibited unless the borrower signs a written request for the review

Why This Is the Correct Answer

C. Submitting appropriate comparable information for consideration is permitted. The regulation expressly allows requests to consider additional appropriate property information. The appraiser remains responsible for evaluating relevance and the supported value; a higher-priced comparable does not guarantee a higher appraisal. Scope and exceptions: Other lender or investor procedures still apply. Permission to provide information is not permission to dictate the result.

Why the Other Options Are Wrong

Option A: Prohibited: any contact at all with the appraiser about value is coercion here

It incorrectly treats every valuation-related communication as coercion.

Option B: Permitted only where the lender also raises the appraisal fee paid

A fee increase is not a prerequisite for this permitted request.

Option D: Prohibited unless the borrower signs a written request for the review

A borrower signature is not the dividing line in the cited provision.

Exam Tip

Request consideration of evidence, not a predetermined number.

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