Hybrid

[timd354]

The only thing that the lender wants is your signature and that shifts liability away from them. .

Yet very, very, very few appraisers have ever successfully been sued by the lender (at least in the residential space), so if that is their goal, it has not worked very well at all as the lenders have utterly failed in their attempt to shift any liability from them onto appraisers, which is why appraisers can purchase an E&O policy with $1,000,000/$2,000,000 coverage in most states for less than $700/year

 

[Meandering]

Oh my,
The "appraiser" (I use the term lightly here) does not have a "client" in the lender. Nope, the lender is the client of the AMC.

And what is the point of stating what most "appraisers" charge? (again appraiser is used lightly by me)

Oh my, who is holding all the liability if that E&O Declaration page is needed?

And what is the "client" (the AMC's) use of the report?


Lots of bad business going on here.

.

 

[Meandering]

What's easy peasy is holding appraisers accountable for the things they are doing, and not holding them accountable for things they aren't doing. As is already required of appraisers in USPAP.

Appraisers are accountable to the scope of the work decisions, and for the scope of the work being credible for the intended use,

and you have no lending regulations that say that the client limiting the scope of the work, providing interior data, to the appraiser, and not allowing the appraiser to view the interior, when an interior inspection is available to anyone who is not the appraiser is sufficiently credible for any lending intended use.

Oh boo hoo,

Make appraisers accountable by limiting their scope of the work.

The only available answer for real appraisers is correctly politically edited to simply, "No thank you".

..

 

[Meandering]

Yet very, very, very few appraisers have ever successfully been sued by the lender (at least in the residential space), so if that is their goal, it has not worked very well at all as the lenders have utterly failed in their attempt to shift any liability from them onto appraisers, which is why appraisers can purchase an E&O policy with $1,000,000/$2,000,000 coverage in most states for less than $700/year

So?

Why write those regulations then, if they don't work in the real world??

More propaganda for the borrowing public???

Oh my.


..

 

[George Hatch]

You're being exceedingly foolish here. Oh dear.

The order you posted has nobody doing any measuring or interior inspection so if an appraiser was present onsite it would only be as a 2055 type SOW. The idea that an appraiser in a 2055 or even a desktop is expected to *know* about the interior without personally seeing it is paranoid beyond all belief.

If you want to make the argument that these are illegal for the lender to order then make that argument (you'll lose, but who cares); but I strongly doubt you have any evidence of appraisers being held accountable for not seeing the interiors or measuring on 2055s, so the same limitations would apply here except there are a couple more.

oh my

What diligence the lenders choose to use in their valuations is between them and their regulators, which already allow them to use less-than-appraisals prepared by non appraisers for certain uses. . We have a hard floor, below which we cannot go, but that hard floor is lower than you and a couple of the other USPAP-deficients here are willing to acknowledge. USPAP says what it says, but more importantly it doesn't say what it doesn't say.

You would flunk the exam.

Oh dear. Clutch mah pearls.

 

[Meandering]

You're being exceedingly foolish here. Oh dear.

The order you posted has nobody doing any measuring or interior inspection so if an appraiser was present onsite it would only be as a 2055 type SOW. The idea that an appraiser in a 2055 or even a desktop is expected to *know* about the interior without personally seeing it is paranoid beyond all belief.

If you want to make the argument that these are illegal for the lender to order then make that argument (you'll lose, but who cares); but I strongly doubt you have any evidence of appraisers being held accountable for not seeing the interiors or measuring on 2055s, so the same limitations would apply here except there are a couple more.

oh my

What diligence the lenders choose to use in their valuations is between them and their regulators, which already allow them to use less-than-appraisals prepared by non appraisers for certain uses. . We have a hard floor, below which we cannot go, but that hard floor is lower than you and a couple of the other USPAP-deficients here are willing to acknowledge. USPAP says what it says, but more importantly it doesn't say what it doesn't say.

You would flunk the exam.

Oh dear. Clutch mah pearls.

Oh my George,

Did you miss the USPAP requirement for verifying the data?

I know it doesn't say "binding requirement" anymore, but it is still a requirement that can't be verified, and then when you look in the IAEG, do you see that EA's for condition and such are not credible, and must be verified?

Oh no, a regulation that must be adhered too, because of the competency rule in USPAP, then the IAEG that says EAs for condition are not credible for lending work.

what to do,

what to do.

.

 

[George Hatch]

Don't lose sight of the point I'm making about not loading into USPAP elements that aren't laid out as such.

SR1-2.e is the section that lays out the requirements for "identify the characteristics of the property that are relevant to the type and definition of value and intended use of the appraisal", and there are explanatory comments included which speak to the topic at hand. I suggest you read it before you use the term "verify" in conjunction with the inspection of the subject property.

Nor does the term "verify" appear in the SOWR. In fact, what the DOES appear in the SOWR is language that suggest that the extent to which a property is inspected is actually a SOWR decision to make according to the type of assignment and intended use at hand; as opposed to a minimum requirement that applies to all appraisals and to which appraisers must invariably adhere.

 

[Meandering]

Don't lose sight of the point I'm making about not loading into USPAP elements that aren't laid out as such.

SR1-2.e is the section that lays out the requirements for "identify the characteristics of the property that are releant to the type and definition of value and intended use of the appraisal", and there are explanatory comments included which speak to the topic at hand. I suggest you read it before you use the term "verify" in conjunction with the inspection of the subject property.

Oh my George,

I believe you should review the IAEG about what is relevant to a "valuation" - as a requirement.

And go to the very end of the IAEG and review their definition of Credible Appraisal Assignment Results.

.

 

[Meandering]

Don't lose sight of the point I'm making about not loading into USPAP elements that aren't laid out as such.

SR1-2.e is the section that lays out the requirements for "identify the characteristics of the property that are releant to the type and definition of value and intended use of the appraisal", and there are explanatory comments included which speak to the topic at hand. I suggest you read it before you use the term "verify" in conjunction with the inspection of the subject property.

Nor does the term "verify" appear in the SOWR. In fact, what the DOES appear in the SOWR is language that suggest that the extent to which a property is inspected is actually a SOWR decision to make as opposed to a minimum requirement that applies to all appraisals and to which an appraiser must invariably adhere.

And I believe you should relook at the USPAP definition of credible along with competency requirements,

Then consider all that in relation to the "relevant evidence" requirement in the IAEG.

 

[George Hatch]

As I have said before, if you want to make the IAEG argument than take your best shot at that, too; because the regulators are demonstrating in real time what they do and don't require of lenders WRT inspections.


Credible is always judged within the context of assignment conditions. Says so in the book. What we seem to be in disagreement about is what the effective requirements for the users are for these assignments.