For consumer credit secured by the borrower’s principal dwelling, an appraisal is $412,000 against a $440,000 contract price. A processor writes to the appraiser: "We send you 6 files a month. Have another look at the value before we decide who gets the next one." Does this message violate Regulation Z’s valuation-independence rule?
Correct Answer
D) Prohibited: linking the next of those 6 files to the value is coercion
D. The implied threat to future assignments is prohibited pressure. The request uses future work as leverage over the valuation, rather than supplying relevant evidence for independent review. The rule covers attempts; the appraiser need not actually change the value for the pressure to be prohibited. Scope and exceptions: A noncoercive request to consider appropriate additional information is different. The added coverage facts prevent generalizing this particular provision to every valuation. Source: 1026.42(a), (c)(1)(i)(C), (c)(3) — https://www.consumerfinance.gov/rules-policy/regulations/1026/42/
Why This Is the Correct Answer
D. The implied threat to future assignments is prohibited pressure. The request uses future work as leverage over the valuation, rather than supplying relevant evidence for independent review. The rule covers attempts; the appraiser need not actually change the value for the pressure to be prohibited. Scope and exceptions: A noncoercive request to consider appropriate additional information is different. The added coverage facts prevent generalizing this particular provision to every valuation.
Why the Other Options Are Wrong
Option A: Permitted: volume of work is a commercial matter outside the valuation rules
Business volume becomes relevant when used to influence independent judgment.
Option B: Prohibited only where the appraiser actually changes the reported value
It incorrectly requires a successful change in value.
Option C: Permitted: the email asks for a 2nd look and names no target value
The threatening context matters even without an explicit target number.
Exam Tip
Challenge evidence through permitted channels; never threaten future work over value.
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