FHA Handbook Updates Confusion And Clarification

[JTip]

We are just looking for an excuse for a raise. That +$50 for the MC form didn't work out well for anybody after they figured out it takes 30 seconds. Your friendly AMC wants justification for a fee increase; 4000.1 is our ONLY hope.

 

[Tejus]

FHA only expects the appraiser to complete what is reasonable and safe.

The FHA Handbook does not contain the phrase "reasonable and safe". This is your interpretation and inconsistent with the FHA Handbook appraisal inspection requirements.

I've already contacted the FHA Staff member (Rob F.) responsible for the FHA Handbook Appraisal Section updates and discussed the Appraisal Inspection requirements with him. Rob has confirmed the Handbook inspection requirements do not match what he claims are the inspection requirements. FHA must correct this. In the meantime, the Appraiser is liable for the FHA Handbook appraisal inspection requirements.

I highly recommend you re-read the original post and the referenced article. Especially enlightening is the sample Prosecutor - Appraiser dialogue. This dialogue could be applied to many of the FHA Handbook Appraisal inspection requirements and illustrates the Appraiser's potential liability.

"Playing dumb" will not save an appraiser from liability when they are on the witness stand.

Until FHA accurately specifies the FHA Appraisal Inspection requirements in writing, everyone should avoid the FHA assignments.

 

[GWISC]

So, 4000.1 was supposed to save us from cross referencing two handbooks and mortgagee letters. I'm guessing there will be a mortgagee letter pretty quick to clarify the new handbook. So much for consolidation of information.

 

[CANative]

The FHA Handbook does not contain the phrase "reasonable and safe". This is your interpretation and inconsistent with the FHA Handbook appraisal inspection requirements.

I've already contacted the FHA Staff member (Rob F.) responsible for the FHA Handbook Appraisal Section updates and discussed the Appraisal Inspection requirements with him. Rob has confirmed the Handbook inspection requirements do not match what he claims are the inspection requirements. FHA must correct this. In the meantime, the Appraiser is liable for the FHA Handbook appraisal inspection requirements.

I highly recommend you re-read the original post and the referenced article. Especially enlightening is the sample Prosecutor - Appraiser dialogue. This dialogue could be applied to many of the FHA Handbook Appraisal inspection requirements and illustrates the Appraiser's potential liability.

"Playing dumb" will not save an appraiser from liability when they are on the witness stand.

Until FHA accurately specifies the FHA Appraisal Inspection requirements in writing, everyone should avoid the FHA assignments.

I talked to the same person and what you're saying doesn't sound like what he said to me.

has confirmed the Handbook inspection requirements do not match what he claims are the inspection requirements

I'm not sure I understand what you mean in the above quote. Can you clarify?

"when they are on the witness stand" Ding! Another reference to judges, courts and witness stands.

 

[Meandering]

I think the 4000.1 has been very good for the appraisal industry.

It got a lot of appraisers to actually read the requirements.

So it does not really matter if you have to see "all" or "most" or the "entirety" of an attic.

What matters is this liability, whether pre-existing or newly discovered, is now known to exist,

and therefore presents a risk that should be financially addressed in the fees, now.

Lucky that borrowers and clients were under charged in the past.

So overall, I think the 4000.1 has been a good thing.

 

[Tejus]

I talked to the same person and what you're saying doesn't sound like what he said to me.

The Sep 29 FHA webinar registration link is:

https://www.webcaster4.com/Webcast/Page/753/10364

I've requested the FHA staff proactively go thru the Handbook appraisal inspection requirements during the webinar, then verbally identify their inspection requirements and identify any differences between the Handbook inspection requirements and their verbal inspection requirements. I don't know if they will do this.

I've also provided them info discussed in this thread, including the Prosecutor - Appraiser dialogue illustrating the Appraiser's potential liability under the new Handbook requirements.

I encourage all Appraisers to participate in the webinar, express their concern over the new appraisal inspection requirements and request FHA clarify in writing their appraisal inspection requirements.

 

[Terrel L. Shields]

I think the 4000.1 has been very good for the appraisal industry.

It got a lot of appraisers to actually read the requirements.

Exactly

 

[CANative]

The Sep 29 FHA webinar registration link is:

https://www.webcaster4.com/Webcast/Page/753/10364

I've requested the FHA staff proactively go thru the Handbook appraisal inspection requirements during the webinar, then verbally identify their inspection requirements and identify any differences between the Handbook inspection requirements and their verbal inspection requirements. I don't know if they will do this.

I've also provided them info discussed in this thread, including the Prosecutor - Appraiser dialogue illustrating the Appraiser's potential liability under the new Handbook requirements.

I encourage all Appraisers to participate in the webinar, express their concern over the new appraisal inspection requirements and request FHA clarify in writing their appraisal inspection requirements.

I have ZERO concerns over the inspection requirements.

 

[Peter LeQuire]

Reading this thread and the several others about the revised HUD manual, and the thread about vacuuming of delivery date commitments into the enforcement purview of a state USPAP enforcement entity, a rational person would think that the methodological and regulatory matrix for SF residential lending-related appraising is totally confused about what it is doing. We observe practiced, proficient, well-intended appraisers (not to mention regulatory officials) not agreeing with what our primary regulatory document means; we have HUD employees who are in positions responsible for overseeing property standards who (it appears) don't know what is required.

We need to start over, it seems to me.

 

[CANative]

12345674890