Submitted by sevans on Mon, 12/01/2014 - 3:34pm

Appendix A of the Guidelines discusses the application of the “Transactions Involving Real Estate Notes” exemption as follows:   

If each note or real estate interest meets the . . . regulatory requirements
for appraisals at the time the real estate note was originated, the institution
need not obtain a new appraisal to support its interest in the transaction. 
The institution should employ audit procedures and review a representative
sample of appraisals supporting pooled loans or real estate notes to determine
that the conditions of the exemption have been satisfied. 

 75 Fed. Reg. at 77467

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