I did a residential appraisal on a 1004 of a high-end home in my market of Central Florida before Christmas directly for an out-of-state lender (no AMC) for an SBA loan. A day after submitting the report I get an e-mail from an appraiser who also holds the SRA and AI-RRS designations, out of South Carolina who informs me that she was retained by the lender to do a review of my report and in an effort to bring it up to USPAP and lender compliancy, my report required multiple revisions.
There were two typos, my fault, my bad, no problem. She wanted the signed engagement letter included in my report and verbiage added that is required on all SBA loans. No problem.
The above issues certainly fall under 'housekeeping' or what many refer to as a 'technical' review with, but she went on to note the following:
A- Remove verbiage addressing that many homes in this market that were purchased back during the bubble / bust years have still not recovered some of the higher prices paid. In support, I included the subject's MLS listing and sale history that was a perfect example. She claimed that what happened back eight+ years ago is not relevant and told me to remove it.
B- Disagreed with my Cost Approach of site contributions of $55,000. And yes, I included support for my estimated vacant site value via allocation.
C- Disagreed with my commentary in support of how the adjustments were supported in terms of paired / matched sales and/or sensitivity analysis because I failed to show the specific analysis to support the methods I used.
This review was done in e-mail format with numbered paragraphs, no limiting conditions, certifications or other Std 3 review compliancy.
I know my feelings on this subject, but am looking for a discussion as to what point a 'technical' review steps into a Std 3 catagory and was the reviewer non-USPAP compliant?
Because this reviewer is not in Florida, she and/or the lender can turn me into the State, but where's my recourse?
And lastly, and the most ironic, when I got her supervisor or the chief MAI appraiser for this lender involved, he told me not to bother with the revisions because for the sake of time and expediency, they approved the appraisal and the loan. So in writing, did he indicate they made a loan on a non-USPAP compliant appraisal?
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