When is a Review Required to meet Std 3?

[George Hatch]

So, they're not asserting jurisdiction over evals or BPOs. Which in absence of any controlling authority dictating otherwise, is their right.

Aren't you a staunch advocate of States Rights? If so, why would this appear to be a conflict or problem for you?

BTW - this still has zero to do with TAF or appraisal standards.

 

[J Grant]

What do you want to bet that if the employee Reviewer were in Florida and opined to Stds 1 and 2, I would have a pretty good chance the FREAB would entertain an admin complaint?

What do I care about the FDIC or other federal agency going after a complaint explained in my original post. On that one - I don't. That's not likely to go anywhere in this particular case, IMO.

That said, I did file a complaint on a Reviewer a few years ago who had personal issues with me (can you imagine that?) and guess who got re-instated and the client 'investigated'? That client is one of my top three clients to this day.

And screw Caesar.

All this "personal" stuff is scary and has no place in reviews. That is why I fail to understand why a reviewer is allowed by a client to email an appraiser (though GH says it is common for him), IMO all communication should go through the client, and again, in the reviews I did, usually the appraiser's name is blacked out for good reason.

the reviewer over stepped bounds in one factor in the email sent, still you got very bristly about it, which perhaps is natural, we can not predict personal reactions I am very against reviewers and appraisers interacting and corresponding, it becomes more about consulting , (if good ) and about fighting (if bad ), either way it veers away from a review of the appraisal itself.

There is a big difference between housekeeping review check list for errors which can be done by a non appraiser and a review addressing value or other conclusions which requires an appraiser, and a problem can arise, as is this case, when an appraiser is hired for a housekeeping review and ends up seeing something in the value or conclusions they take it upon themselves to address.

 

[Joyce Potts]

I am 'bristly' about reviewers getting away with this all the time and the typical appraiser not knowing enough to discern when it steps into a Std 3/4 review. Or, if they push back, they've lost a client.

 

[Stone]

All this "personal" stuff is scary and has no place in reviews. That is why I fail to understand why a reviewer is allowed by a client to email an appraiser (though GH says it is common for him), IMO all communication should go through the client, and again, in the reviews I did, usually the appraiser's name is blacked out for good reason.

the reviewer over stepped bounds in one factor in the email sent, still you got very bristly about it, which perhaps is natural, we can not predict personal reactions I am very against reviewers and appraisers interacting and corresponding, it becomes more about consulting , (if good ) and about fighting (if bad ), either way it veers away from a review of the appraisal itself.

There is a big difference between housekeeping review check list for errors which can be done by a non appraiser and a review addressing value or other conclusions which requires an appraiser, and a problem can arise, as is this case, when an appraiser is hired for a housekeeping review and ends up seeing something in the value or conclusions they take it upon themselves to address.

Others have mentioned it before, but there is a whole world of appraisal where communicating with the reviewer isn't just okay, but an expected part of the process. Many of these assignments are complicated, but not all of them. Good reviewers still keep it professional and about the report. I get that many appraisers never deal with this type of situation, but it is certainly part of the process for many appraisers and reviewers.

I will admit that with most reviewers, it is fine, but when you have someone who is a pain, it is easily the worst part of the job, IMO. But, it is part of the job for me and no matter how much I'd prefer never to have anyone question my work, they do and I have to answer. Part of the gig for a lot of non-lending type of work.

 

[bnmappraisal]

But, it is part of the job for me and no matter how much I'd prefer never to have anyone question my work, they do and I have to answer.

I like your whole post, but definitely agree with this part

To me, this is the part that "keeps us on our toes" per se.

 

[RCA]

Too much paranoia out there.
Reviewers are not in the filing complaint business. They are hired to do a reviwe for their client, and it is up to client what to do, if anything about the appraisal, and possibly about an appraiser- if appropriate, But usually the issues are about the work itself. Though an individual might be the exception I doubt most appraisers doing a review would file a complaint unless they see something so egregious.

Imo reviewers are in more jeopardy in getting a complaint filed against them from an appraiser whose report they reviewed, since an appraiser can take it personally,.

Of course, you could look at that way. We might ask which "reviewers" you are referring to. FDIC reviewers? Trying to mop up after a bank goes belly-up? I was just reading through Peter Christensen's "Risk Management". It seems to me the FDIC can be very very aggressive.

Yea, I think your opinion is just that.

 

[Terrel L. Shields]

It seems to me the FDIC can be very very aggressive.

And they argue that the statutes of limitations does not apply to them, therefore, could come back on work done 10 plus years ago.

 

[Elliott]

Haven't been following this thread, but thought I'd throw in an observation about the depth of "Reviews."

I'm betting a real Standard 3 review has very, very seldom ever been done. What are commonly called reviews have very specific, limited scopes, dancing over problematic standards. The review is designed by stakeholder types for a specific purpose so they can stamp the report 'approved' or 'not approved' to their review standard.

Does anyone know of a review which became an investigation by a board? I would think they would be extremely rare.

 

[Terrel L. Shields]

Does anyone know of a review which became an investigation by a board?

Since most are in house and done by non-appraisers, I'd say very few. I do recall many moon ago, some aggressive appraisers who were doing reviews were turning in the appraisers they were reviewing. The investigator then required the review be sent in as well. Sometimes both the reviewer and the appraiser got to stand before the board and take their medicine. It got so bad the state director had to editorialize in the newsletter to reviewers to review their own work. So how many Std 3 reviews are really USPAP compliant? Who reviews the reviewer? I think George and Joyce are having a little problem wrapping their head around the issue that most states exempt bank employees from USPAP regulation. And non-mandatory states don't have to exempt them.

When I first started the reviews that were Std 3 compliant were either large complex properties or were a requirement of FHA who wanted a review of newbie appraisers. The rest were administrative in nature and done in house by the loan officer or a designated in house appraiser.

One of my former clients used to review our poultry farm appraisals one and all, but mostly by their CGs in house. But if overloaded they used to review them with outside appraisers who did do a full Std 3 review. Also, on FmHA backed farm loans, FmHA would review them in house and I've answered questions in both AR and OK. But again, they were professional appraisers used to correct errors in reports, rather than just resort to playing "gotcha".

 

[Eli]

I am 'bristly' about reviewers getting away with this all the time and the typical appraiser not knowing enough to discern when it steps into a Std 3/4 review. Or, if they push back, they've lost a client.

It ain't right.