Can a Mortgagee obtain two concurrent Home Equity Conversion Mortgage (HECM) appraisals before the FHA collateral risk assessment, in anticipation of a requirement for a second appraisal?

No.  The Mortgagee must wait for the FHA collateral risk assessment to determine if a second appraisal is or is not required.  Mortgagee Letter 2018-06 does not allow for an exception to HUD’s requirements regarding ordering second appraisals and appraiser independence.

For additional information see Mortgagee Letter 2018-06 available at: 


All policy information contained in this knowledge base article is based upon the referenced HUD policy document. Any lending or insuring decisions should adhere to the specific information contained in that underlying policy document.

Topic Number: 2018-0023