An appraiser had an original effective date of 3/26/2025. The appraiser then completed an exterior only inspection on 4/11/2025 and changed the effective date of the appraisal to 4/11/2025. A credible off-market sale that was the most accurate indicator of value was then added to the original report that had a closing date after the original effective date. Is changing the effective date of the appraisal based on an additional exterior of the inspection acceptable via USPAP and FNMA?
It; 's a tricky slope- what kind of review are you doing, a 2000 field review ( or something different )
I did quite a few field reviews at one time and I did not make judgments like this is acceptable or not acceptable or this is good or bad. I rarely invoked a USPAP violation either - a few rare exceptions. Let the client decide what was good or bad or acceptable or not.
I would instead point out discrepancies, with regard to the fact that the certified person did this, but the appraiser did that. It was neutral on my part, no judgment made, just a fact. As a reviewer, you need to express factual statements and not make your own personal calls on a situation (that could bet teh reviewer in trouble with USPAP police )
So note any discrepecnies about what this appraiser did, and leave it up to the client to enforce or complain or not .
If the original appraisal was on a 1004 or stated an interior and exterior inspection was done on X eff date, but then they made a later date additional exterior only inspection, then point it out. Post 6 aabob e made a good point - if they had two values on two different dates, one is a prior service and the prior service needed to be disclosed a factual issue
We are obliged in a review to call out factual errors, especially those that materially affect value -I would not comment that X is acceptable or not wrt USPAP or FNMA. (Unless your form asks for it?) You can state that USPAP requires a prior service disclosure in the report and it was not made ( if tht is the case)
Reviewing can give one a headache....not easy.