- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
Primarily because that definition was imposed on them by the govt. Which that could change at any point if the decision makers had reason to do it.George your right it does not conflict with USPAP but does with Fannie-freddie-FHA-VA and almost any loan production assignment.
Bert has commented about the downsides of using that definition in appraisal assignments being used by a lender and IMO much of his reasoning for that makes sense. I think the lenders should rephrase the question of "what's the value?" into a more explicit "what's the value to us as a lender?". Whether as a supplemental value opinion or by swapping it in for MV. That way they could call out their assumptions independent of what a borrower was trying to do.
But in the meantime the primary virtue of using a single definition of value for these assignments is that doing so works towards consistency and uniformity - even if imperfect. More is always better than less.
I think lenders should be adjusting their underwriting to reflect their exposure to different levels of risk at different points of the RE cycle. But, they can't be given more discretion without also being given more responsibility for their outcomes. Which we as a society never seem to follow through with. Hence the repeated cycles revolving around the effects of the same moral hazard.