Forgive the length. I haunt the forum alot, mainly trusting the vets here will eventually get to the core of an issue in a more quick-witted meme-orial way...
This is an issue with valuation pros limiting themselves to the label of 'appraiser', really meaning 'state licensed appraiser'. We are too used to relying on civil gov't to qualify, define, dictate, & protect our profession. The big picture is valuation, not appraisal; appraisal is a subset of valuation even per holy writ USPAP. If a person wants to stay in the subset, fine, be blessed. But there is a bigger market out there in addition to federally related transaction/USPAP/FDIC/FMNA/Comptroller/de minimus bank loan market.
When a market-derived demand appears, the only real question is whether I am in a position to satisfy it by offering expanded valuation services. I personally like to get ahead by serving others, not appealing to the king or bemoaning change in tastes.
Where the State gives recognition (favors), the State also controls. But, in those instances where no civil gov't regulations require an appraisal (subset of valuation)...If you are not marketing yourself only as a 'licensed appraiser', &/or the prospective client is not engaging you with expectation you will perform one, no appraisal-centric constraints apply. Neither should they.
Yes, we can perform a valuation without performing an appraisal. An appraisal is always a valuation, though. Valuation is a bigger 'circle'. There seems to be confusion on this issue.
Go, frolic in the new grass, just make sure you & the client are on the same page about what your role is in providing the non-appraisal valuation service. Get comfy wearing multiple hats for the sake of your clients. With correct communication and well-written agreements/reports, they need not be confused about what head dress you have on each specific time. Again, it is for the sake of the client that I expand my services outside the circle of appraisal only.
If I exclusively market myself as an appraiser, so that a prospective client hires me based on that assumption, yes I will be bound in the smaller circle (or the client requested, but that's their choice not mine). That is not because appraisal trumps all, though. It's because I've chosen to restrain myself in what products are supplied.
If, in fact, what I ALWAYS am is an appraiser then, to me (not USPAP tho), every 'eval' is in fact an appraisal 'subject to...' That is not because USPAP said every valuation is automatically an appraisal, not because appraisers always do it better because they are appraisers by god, not because that evaluator did it worse then me because they're not an appraiser by god, not because they didn't show a grid with three comps or some advanced mathematical gymnastics or whatever, no. It is because I CHOSE that I would only perform appraisals (a subset of valuation). The result many times is I either price myself out of an assignment on one side or get paid a lower $ per unit of time on the other.
As an 'appraiser only', I WILL always 'comply'. And I will take more time due to scope creep/AMC stips/regulatory satisfaction & have to charge more even though the client may not need that level of 'service'. You wanna know how to sock it to AMCs? Take part of their business by doing 'evals' (below de minimus valuations, stocking stuffer annual reviews, etc). For clients who only need something 'quick & dirty', a number, something on a few pages based on my experience & built trust, something where every word has meaning not 75% legal-ese/bureaucrat-ese/compliance-ese that doesn't really cover my backside anymore anyway, they should have it.
Clients are prospective buyers of our services, and yes they have a say in a (somewhat) open market of what level of product 'quality' is desired, the civil gov't or myopic protests of 'state certified appraiser only' aside.
As a 15+ year Realtor, sales agent, & 'state certified appraiser', it is my conclusion appraisers are the best valuation experts. They generally have greater applied knowledge, experience, & ethics - whether imposed from the outside or, hopefully, inculcated from the inside over time. We've been in the game & passed through the fire. That is exactly WHY we should seek to expand our services outside the little circle & position ourselves in the all-encompassing big circle of real estate valuation.
