1004 D Update on New Construction Unit

[Webbed Feet]

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Please, someone, send me the name of any appraiser who has ever been sanctioned by an appraisal board only for providing the 1004D/442 Form just the way it was designed by the beloved GSE's.

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I'll say this again ........... just complete the blasted form the way it's designed, and send it ONLY back to the client. Appraisers are not being paid enough to do a complete new appraisal report with associated exhibits, grids, etc., when answering 'yes' or 'no' is the only item in play. Either that, or just refuse to do this kind of assignment for the hundred bucks or so that is offered ..... and loose a client in the end.

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I have to chime in with the above is all a wonderful rant, I very much dislike the 1004D as well. I think appraisers nationwide should have thrown a revolt over both the 1004D and the 1004MC forms. But beyond that, VolcanoLvr, your advice has potential to get many appraisers in trouble.

http://oregonaclb.org/pdf/Spring2008Newsletter.pdf

If you really believe the head of a state board would spend his time writing a two page article over the hazards of the 1004D form (pages 8 and 9) when his state board was NOT having to act on any problems regarding it..... then I suppose you'll say he had nothing else better to do that week than draft and edit so much information for open publication to an entire state of appraisers.

 

[VolcanoLvr]

Well folks, I guess we'll just have to agree to disagree.

But, I have never said that an appraiser should not complete the comment section in the Update part of the junky 1004D. My position is that a carefully written 'summary' can be included there to describe SoW, research done, conclusions, etc., and a statement that the entire prior report (including certifications) is incorporated by reference (especially if the appraiser is the same appraiser for the original report).

Mr. Keith, who I've had the pleasure of meeting (and who is no longer the appraiser agency manager in OR), goes to great length to explain that an 'additional addendum' must be included with the 1004D. I disagree with that assumption/recommendation as an absolute requirement. However, I also realize many appraisers don't know how to write short, concise, bullet-point sentences using as few words as possible in the comment section, so they may need to add an addendum.

The only way to 'revolt' against this crappy form, and the equally crappy MC form, is to quit doing mortgage lending assignments. But that's not going to happen, and appraisers are stuck with them.

Meanwhile, life goes on and thousands of appraisers complete 'just' the 1004D Update with a summary comment or two, without all the multiple gyrations contained in USPAP.

I'm still waiting for evidence that any appraiser has been sanctioned for doing so. And I doubt Mr. Keith had to neuter anyone in Oregon over this process while the regulator. And I also doubt the majority of Oregon appraisers (or elsewhere) do an entirely brand new appraisal with associated exhibits when the 1004D Update is requested, especially at the low fee typically offered.

 

[VolcanoLvr]

Final point, then I'm finished with this discussion...........

The Scope of Work on the 1004D Update specifically says that the "appraiser MUST CONCUR WITH THE ORIGINAL APPRAISAL."

Then the form wants the appraiser to verify if the original appraised value is the same 'today' as it was 'yesterday' .... which is why this stupid form was designed.

If IT NOT THE SAME, you cannot "CONCUR" with the original appraisal.

The absurdity of this instruction is astounding. But it's not much different than other instructions and explanations provided by the GSE's on THEIR OTHER FORMS.

 

[CANative]

The "same today as it was yesterday" whether you answer yes or no is an appraisal and must meet the requirements of SRs 1 an 2. That's what you're not getting.

 

[Webbed Feet]

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I'm still waiting for evidence that any appraiser has been sanctioned for doing so. And I doubt Mr. Keith had to neuter anyone in Oregon over this process while the regulator. And I also doubt the majority of Oregon appraisers (or elsewhere) do an entirely brand new appraisal with associated exhibits when the 1004D Update is requested, especially at the low fee typically offered.

Considering that I am not aware of any state that actually lists what form was used when publishing sanctions against appraisers, I'll just offer for YOU to go spend your time proving that no appraiser ever has been sanctioned over your described lazy use of the 1004D form. My evidence was a two page publication by a state appraisal board, and I'll happily accept it as plenty of evidence.

Next, and I'm sure CANative hates reading me agreeing with him, but a 1004D top half IS a brand new appraisal. He is right, you keep either intentionally not getting it, or you just don't get it.

Final point, then I'm finished with this discussion...........

The Scope of Work on the 1004D Update specifically says that the "appraiser MUST CONCUR WITH THE ORIGINAL APPRAISAL."

Then the form wants the appraiser to verify if the original appraised value is the same 'today' as it was 'yesterday' .... which is why this stupid form was designed.

If IT NOT THE SAME, you cannot "CONCUR" with the original appraisal.

The absurdity of this instruction is astounding. But it's not much different than other instructions and explanations provided by the GSE's on THEIR OTHER FORMS.

Ahhhhh...... I'm reasonably certain you just lost everyone posting that if the past value and current value are not the same that the original appraisal cannot be concurred with. Me thinks an appraiser certainly can concur with a prior appraisal report regardless of what value is opined on a later date. Both value opinions, the past one and the current one, stand alone.

I accidentally posted bottom half when I meant top half earlier, perhaps you misposted too?