Discussion in 'Fannie Mae, Freddie Mac, USPAP' started by xm72mhd, Jun 29, 2007.
Got this in the mail today. What think you?
Sooooooo Edd. Are you saying you've been making "modifications" to the certification rather than just "appending" them?
Actually all I have advised around here is to "clarify" the darned thing with some language rather similar as follows:
It is not verbatim, but does it do violence to anything other than an underwriter's sensibilities?
I sense Fannie must have awakened from hibernation again. I thought this would go away with Mark Simpson. NOT?
Why is this of concern again?
I see nothing wrong with RELS/FNMA statement. I also agree with them that there are many people connected with the mortgage transaction that might need to use the appraisal report. They do not mention hazard insurers as a user and that would be my only objection if that was intended.
Well, of course you don't, it is verbatim the compromise language struck between Fannie and the mob. And if your appraisals are not being used to establish insurance value monkeys don't swing in trees.
All this was hashed on here through and through even before the thing became effective, but why is it rearing its stupid head again?
YOU brought it up, Edd....that's why it is "rearing its stupid head."
Why would hazard insurers want the market value? Granted: they, the insurers, would like the cost replacement value but Fannie says it is not needed. So, where is the conspiracy?
If you are required by the client to perform the cost approach and you decide you want to be a good guy and do it, charge for it and make damn sure it is correct. However, Edd, as an attorney, can you not devise a simple disclaimer that says "not valid for hazard insurance purposes?
Just pass the Vaseline, please.
Joyce!!!! Are you THAT easy? LOL
hmmm...I think its likely because of the secondary b & c market failures on wall street...they're looking for anything else they can use to try to blame anyone other than themselves...otherwise they have to buy all the bad loans back.
Note that the July 2005 USPAP Q&A appeared to settle this before it ever became an issue. Further, many of the state appraisal boards have universally rejected cert 23, with their own recommended language.
I'd say if you use it as scope of work identification, you'll do fine. Per the above Q&A, you have to id the intended use/user at the start of the undertaking of the assignment. As such, you can either id mortgage use, or insurance use, etc...or not.
Let me try again. Rels brought it up by sending it to one of the guys here on their panel. I am sharing it with you. The RELS stuff says cert 23 modifications are a problem and then identifies all those things that it considers a modification, then says appraisers can clarify with the negotiated language.
Frankly, it is curious to me why RELS even mentioned it. Sorry, that's what I meant by "rearing its stupid head", I wasn't talking about yours. I guess you knew that.
I don't know anything about a conspiracy. Do I?