Lender Appraisal Processing Program (LAPP) - VA
The Lender Appraisal Processing Program (LAPP) is a program established and administered by the Department of Veterans Affairs (VA) that delegates appraisal review authority to qualified lenders for VA-guaranteed loans. Under LAPP, approved lenders employ VA Staff Appraisal Reviewers (SARs) who are authorized to review appraisal reports and issue the VA Notice of Value (NOV) directly.
This program delegates the appraisal review and reasonable value determination process to VA-authorized lenders, allowing them to receive appraisal reports directly from appraisers and process them without direct VA involvement for each case.
Purpose and Key Aspects
The primary purpose of LAPP is to accelerate the closing of VA loans by empowering qualified lenders to manage the appraisal review process internally. (VA Pamphlet 26-7, Chapter 15, Section 15-1.a.)
Key aspects of LAPP include:
- Delegated Authority: LAPP delegates certain appraisal processing responsibilities to approved lenders, streamlining the process compared to appraisals processed directly by VA staff. It allows lenders with automatic authority to expedite the appraisal process by performing their own appraisal reviews.
- SAR Role: Lenders participating in LAPP must have VA Staff Appraisal Reviewers (SARs) who are trained and VA-approved to perform appraisal reviews, ensure appraisals comply with VA requirements and Uniform Standards of Professional Appraisal Practice (USPAP), and issue NOVs.
- Streamlined Process: It allows lenders to receive appraisal reports directly from appraisers and process them without direct VA involvement for each case.
- Oversight: The VA maintains oversight through case reviews and can amend or withdraw LAPP authority for non-compliance.
The LAPP program is designed to streamline the VA loan process while maintaining appraisal quality and adherence to VA standards.
How LAPP Works (Four Steps)
- Appraiser Assignment: The LAPP lender requests a VA-assigned fee appraiser and a VA loan number, identifying the case as "LAPP."
- Report Delivery: The VA-assigned appraiser sends the appraisal report directly to the LAPP lender's VA-approved Staff Appraisal Reviewer (SAR).
- SAR Review and Value Determination: The SAR reviews the appraisal for completeness and conformity with VA requirements, determines the reasonable value of the property, and identifies any conditions for VA loan guaranty. The SAR then issues a Notice of Value (NOV) to the veteran buyer.
- Loan Underwriting and Guaranty Request: The LAPP lender underwrites and closes the loan on an automatic basis and requests VA guaranty. (VA Pamphlet 26-7, Chapter 15, Section 15-1.b.)
VA Staff Appraisal Reviewer (SAR)
A VA Staff Appraisal Reviewer (SAR) is a Department of Veterans Affairs (VA)-approved employee of a VA loan lender or servicer who is authorized to exercise delegated authority under either LAPP or the Servicer Appraisal Processing Program (SAPP). SARs are responsible for reviewing appraisal reports for properties securing VA-guaranteed loans and issuing Notices of Value (NOVs) without direct VA involvement, after completing specific training and test case requirements.
The SAR plays a critical role in the delegated appraisal process for VA-guaranteed loans, ensuring the accuracy and compliance of appraisal-related activities. This is particularly important for existing VA-guaranteed loans (e.g., for refinancing or liquidation appraisals) and new loan originations. The SAR acts as the delegated authority for appraisal review, determining the reasonable value of properties for VA loan guaranty purposes.
SAR Qualifications and Requirements
To qualify as a SAR, an individual must meet stringent requirements to ensure impartiality and competence:
- Employment Status: Be a full-time salaried employee of the LAPP lender or SAPP servicer.
- Work Experience: Possess at least three years of work experience that qualifies them to competently perform administrative appraisal reviews. This experience should demonstrate:
- General knowledge of appraisal principles, methods, practices, and techniques.
- Ability to review others' work and recognize deviations from accepted appraisal principles.
- Ability to detect errors in computations and unsupported conclusions.
- Knowledge of general realty practices and principles related to real property valuation, skill in data collection, and ability to prepare clear reports are desirable.
- Three years of experience related to the Housing and Urban Development (HUD) Direct Endorsement (DE) program satisfies the experience requirement, provided other application requirements are met.
- Location: There is no restriction on the SAR's physical location.
- Geographic Authority: Once training and initial case reviews are complete, a SAR's LAPP authority extends to any state where the lender has VA Automatic Lenders (Supervised and Nonsupervised) authority. The SAR is responsible for staying informed about local VA processing requirements unique to the VA jurisdiction where a property is located.
SAR Responsibilities
SARs are responsible for:
- Appraisal Review: Reviewing appraisal reports for completeness, conformity, and compliance with VA directives, Uniform Standards of Professional Appraisal Practice (USPAP), and the VA's definition of reasonable value. They must resolve any concerns with the appraiser. This includes:
- Determining the property's acceptability for VA Loan Guaranty purposes, considering VA Minimum Property Requirements (MPRs).
- Assessing the appropriateness, completeness, consistency, and accuracy of the fee appraiser’s reasonable value determination.
- Performing a due diligence function, not acting as a co-signer or supervisory appraiser.
- Concurring with the fee appraiser’s recommendations, noting any disagreements in WebLGY.
- Not exerting pressure or undue influence on the appraiser to change information or reach a predetermined value.
- Determining that the appraiser used appropriate and reasonable methodologies, made consistent conclusions, and complied with applicable VA requirements.
- Identifying any conditions that must be met prior to VA guaranty of the loan.
- NOV Issuance: Determining the "as-is" value of the property, supported by the appraisal report, and inputting data into The Appraisal System (TAS) to generate an NOV. They must issue a written NOV to the veteran buyer, including any conditions.
- Timeliness: Issuing the NOV within five business days from the time the completed appraisal is uploaded into WebLGY, unless delays are beyond their control.
- AMS Review: Reviewing the electronic scoring results from the Appraisal Management System (AMS) and ensuring that any high alerts are addressed in WebLGY notes.
- Quality Control: Contributing to the lender's/servicer's overall quality control plan for VA loans.
Cursory Appraisal Review
For low-risk appraisals identified by the Appraisal Management System (AMS), a SAR may perform a streamlined "cursory appraisal review." This review includes:
- Reviewing the sales comparison grid.
- Confirming the report contains required photographs that accurately reflect the appraiser’s description of the subject and comparable properties.
- Identifying all VA Minimum Property Requirements (MPRs) that must be addressed before the property can secure a VA-guaranteed loan.
- Reviewing any alerts identified by the AMS, specifically documenting any high alerts in WebLGY notes.
- Identifying any additional conditions that must be included on the Notice of Value (NOV).
SARs must indicate in WebLGY whether a cursory review was performed. Findings during a cursory review may lead to the review process being elevated to a comprehensive review if more significant issues are identified.
SAR Application and Approval Process
- Application Submission: SAR applicants, along with a nominating senior officer from their servicer/lender, must jointly complete the SAR application and attach a resume detailing their experience. A $100 processing fee is required.
- Preliminary Approval: Upon preliminary approval from VA Central Office, the nominee can schedule SAPP SAR training.
- Training and Certification: To obtain final approval, a SAR must:
- Attend SAPP SAR training provided by VA Central Office staff.
- Successfully complete five initial test cases to demonstrate comprehension of VA liquidation appraisal review requirements. These test cases are submitted in TAS and reviewed by VA Regional Loan Center (RLC) staff, who issue the NOV for the test cases within five workdays. Exceptions may apply for SARs with prior LAPP experience or if an experienced SAR trains and supervises the new SAR.
SAR ID Number and Transferability
- VA issues a permanent identification (ID) number to each approved SAR. This ID number is retained by the SAR even if they become employed by a different servicer/lender.
- If a SAR already has a LAPP SAR ID number, it will also be used as their SAPP SAR ID.
Authority Upon Changing Employers
- If a SAR begins work for a new servicer/lender, their SAPP/LAPP authority automatically ceases and does not transfer.
- The new employer must submit a new SAPP/LAPP application and a $100 processing fee to reinstate the SAR's authority.
- A waiver for training and case review requirements may be requested if the SAR's VA-issued ID number is included on the application and they have processed SAPP/LAPP cases within the last year.
- Changes in a SAR's employment or a lender's status require notification to the VA. If a SAR was the lender's only SAR, the lender's LAPP eligibility is also terminated upon their departure.
Conflict of Interest
A SAR must not have any conflict of interest that could compromise their impartiality and independence in their role of reviewing appraisals and determining property values for VA loans. Prohibited activities include:
- Being on the Department of Veterans Affairs (VA) fee appraisal panel.
- Being employed by or performing appraisal review services for another lender or servicer.
These prohibitions ensure that the SAR's judgment is solely focused on the objective review of the appraisal and the determination of reasonable value for the employing organization, free from external influences or competing interests. The SAR's primary loyalty and focus must remain with their employing servicer's SAPP operations or lender's LAPP operations.
Electronic Signature
The SAR's login to WebLGY with a unique username and password constitutes an electronic signature on the NOV, eliminating the need for an ink signature.
Lender Eligibility and Responsibilities
Eligibility Requirements for Lenders
To qualify for LAPP authority, a lender must:
- Be an VA Automatic Lenders (Supervised and Nonsupervised) already authorized by the VA.
- Request LAPP authority.
- Meet specific qualification criteria outlined in VA Pamphlet 26-7, Chapter 15, related to experience, financial stability, and quality control.
- Maintain an effective Lender Quality Control System that is independent of the lender's loan production operation. (VA Pamphlet 26-7, Chapter 15, Section 15.01.a, 15.02.a.)
Lender Responsibilities and Due Diligence
LAPP lenders are expected to exercise Due Diligence in processing LAPP cases. This refers to the standard of care expected from a reasonable and prudent lender, involving strict adherence to VA policies, regulations, and statutory requirements, as well as protecting the lender's investment in the subject property. (VA Pamphlet 26-7, Chapter 15, Section 15.06.a.)
This encompasses:
- Complying with all applicable VA policies and procedures.
- Complying with all VA regulations.
- Complying with all statutory requirements.
LAPP authority is a privilege delegated at VA's discretion and can be amended, suspended, or withdrawn if the lender fails to comply with requirements or exercise due diligence. (VA Pamphlet 26-7, Chapter 15, Section 15.06.a, 15.06.c.)
LAPP lenders are also responsible for resolving any timeliness issues involving their authorized agents and branch personnel in the NOV issuance process. If a LAPP-approved lender does not process an eligible property under LAPP, a detailed explanation must be provided to the VA for why VA staff are being requested to issue the NOV.
Lender Quality Control System
To qualify for and maintain LAPP authority, a lender must establish and maintain an effective quality control (QC) system. This system is crucial for ensuring the adequacy and quality of the lender's Staff Appraisal Reviewer (SAR) activities and overall compliance with VA requirements.
Key requirements for the QC system include:
- Independence: The QC system must be independent of the lender’s loan production operation to ensure objective oversight.
- Reporting: The QC system must provide for written notification of deficiencies to the lender's senior management or chief executive officer at least quarterly.
- Reviewer Qualifications: QC personnel should possess a basic familiarity with appraisal theory and techniques and the ability to prescribe appropriate corrective actions. Reviews of SARs' work may be performed by an independent party or an independent internal audit division reporting directly to the chief executive officer.
- Frequency and Scope of Reviews: Desk reviews of each SAR’s appraisal reviews must be performed on a routine basis (monthly or quarterly). The sample size should be no less than 5 percent of the SAR’s LAPP cases processed monthly or a minimum of five cases. Procedures must exist for expanding the scope if a pattern of deficiencies is identified.
- Review Criteria: QC reviews should assess the overall quality of the SAR’s appraisal review, the acceptability of the property in light of VA minimum property requirements, and the appropriateness of the reasonable value determination.
- Maintenance of VA Publications: The QC system must ensure that all current pertinent VA regulations, directives, and other releases are maintained and immediately available to QC personnel and SARs.
- Corrective Action: Senior management must promptly initiate and document actions to correct identified deficiencies and provide SARs with corrective instructions.
- Review of VA Fee Panel Appraisals: Random field reviews of VA fee panel appraisals should also be performed, either by the SAR or an independent appraiser. Substantive negative findings must be formally reported to the VA Regional Loan Center. (VA Pamphlet 26-7, Chapter 15, Section 15.02.a-g.)
The senior officer of the lender must certify on each SAR's application (VA Form 26-0785) that the QC system meets these requirements. (VA Pamphlet 26-7, Chapter 15, Section 15.02.a.)
The Appraisal System (TAS) / Appraisal Management System (AMS)
The Appraisal System (TAS), also referred to as the Appraisal Management System (AMS) by the Department of Veterans Affairs (VA), is a comprehensive electronic, rules-based software system. It is used by the VA and its authorized participants, including lenders and servicers, for managing appraisal-related processes, obtaining loan identification numbers, and assisting in the appraisal review process for VA-guaranteed loans.
Key Functions and Functionality
TAS serves multiple critical functions within VA loan programs, encompassing both administrative processing and appraisal risk assessment.
Appraisal Processing and Loan Identification
TAS is a critical tool for servicers and SAPP Staff Appraisal Reviewers (SARs) within the Servicer Appraisal Processing Program (SAPP), and for lenders requesting loan numbers.
- Appraisal Request: Servicers use TAS to request appraisals by completing VA Form 26-1805, VA Request for Determination of Reasonable Value. TAS automatically notifies the assigned appraiser via e-mail.
- Test Case Submission: SARs submit their initial test cases in TAS for VA review.
- Interest Rate Reduction Refinancing Loans (IRRRLs): TAS is the designated platform for lenders to request new loan numbers for IRRRLs from the VA. While IRRRLs generally do not require an appraisal, TAS is used to obtain the necessary loan identification number for these refinancing transactions. Lenders request a new loan number through TAS without requesting an appraisal.
Appraisal Review and Risk Assessment
When an appraiser uploads a completed appraisal report into WebLGY, TAS (referred to as AMS in this context) automatically reads and scores the appraisal. This electronic scoring helps SARs to:
- Quickly assess appraisal risk.
- Determine property eligibility.
- Ensure compliance with VA policy.
- Identify potential over/under-valuations and appraisal quality issues.
TAS flags items as potentially problematic and determines compliance with VA appraisal requirements, industry-accepted appraisal principles, and Uniform Standards of Professional Appraisal Practice (USPAP).
Alerts and Review Levels
TAS provides alerts (high, medium, low) based on VA's business rules:
- High alerts must be addressed and documented in WebLGY notes.
- Medium and low alerts require careful review but do not necessarily require comments.
- TAS scores guide the level of review:
- Low-risk appraisals may undergo a cursory review.
- High-risk appraisals require a comprehensive review.
- Properties that are complex, rural, or new/proposed construction may receive an "N/A" score due to lack of market data, which also necessitates a comprehensive review.
SARs must use TAS as a tool to ensure appraisals are accurate, complete, and that the property is properly valued according to VA-accepted appraisal principles and practices.
Integration with Notice of Value (NOV) Issuance
The Notice of Value (NOV) is a critical, formal written document issued by the VA or a VA-approved Staff Appraisal Reviewer (SAR) that communicates the VA's determination of the reasonable value of a property and specifies conditions for loan guaranty. TAS plays a crucial role in the issuance of NOVs, particularly for Servicer Appraisal Processing Program (SAPP) cases.
NOV Generation in SAPP Cases
For SAPP cases, TAS facilitates the generation of NOVs for liquidation appraisals.
- Appraisal Review: A SAR reviews a liquidation appraisal report for completeness, conformity with industry standards, and compliance with VA directives.
- Value Determination: The SAR determines the "as-is" value of the property, ensuring it is supported by the reviewed appraisal report.
- NOV Generation: The SAR accesses TAS in the Veterans Information Portal (VIP), selects "Issue Liquidation NOV," and inputs the required data to generate the NOV.
- During the initial approval process for a SAR, test case NOVs are saved in TAS and reviewed by VA Regional Loan Center (RLC) staff, who then issue the final NOV. Once a SAR receives final approval, they can issue NOVs directly without VA involvement, except for complex cases which can be submitted to the RLC for processing.
Electronic Scoring Integration with WebLGY
When an appraiser uploads a completed appraisal report into WebLGY, TAS (referred to as AMS in this context) automatically reads and scores the appraisal. This electronic scoring helps SARs in WebLGY to quickly assess appraisal risk and determine property eligibility, which directly informs the content and conditions of the NOV.
Access
TAS is accessed by SARs through the VA E-Appraisal application within the Veterans Information Portal (VIP).
Property Eligibility and Exceptions
Most properties eligible for a VA loan can be processed under LAPP. However, specific exceptions include:
- Master appraisals
- Foreclosure appraisals
- Those involving partial release of VA loan security
- Those involving HUD value determinations. (VA Pamphlet 26-7, Chapter 15, Section 15.07.a.)
Properties sold by lenders (e.g., foreclosed or "Real Estate Owned" properties) are generally not eligible for processing under LAPP and must be ordered and processed as Individual (IND) appraisals.
Case Transfers and Non-LAPP Lenders
- Transfer of Cases: An appraisal report and case number may be transferred to another LAPP lender in VA WebLGY by a SAR of the original lender. However, an NOV issued by a SAR is not transferable; the new lender's SAR must issue a new NOV.
- Non-LAPP Lenders: If a new lender does not participate in LAPP, the Veteran's request to change lenders must be submitted to the VA Regional Loan Center (RLC), and the RLC will issue the NOV.
Related Programs
LAPP is analogous to the Servicer Appraisal Processing Program (SAPP), which is for servicers.
Source material
- Chapter_13
- Ch10_Appraisal_Process_NEW
- Chapter_15
- Index
- Chapter_18
- chapter6 refinancing loans
Study the full exam sections
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