This issue goes back to the vendor/third party service provider relationship and the risk management of that relationship. If the bank is not conducting adequate due diligence on the third parties who are selected to perform services for the bank, and the bank’s customers, then there is that possibility that an element of discrimination could creep in without the bank’s knowledge-unless they have a robust appraisal review program in place to detect issue such as this. Just like in any other vendor/third party issue, the responsibility will always stay with the bank, no matter what.
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Learn more about Maureen Carollo’s Appraisals and Fair Lending, Including ROVs webinar.