1004D "prior involvement" disclosure

[andrew81]

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The essence of the original post is that other threads have described the FNMAE requirement that the "prior involvement" statement must be included on the form page where an appraiser is required to sign, and not elsewhere in the report, in order to avoid a USPAP violation. If that is indeed accurate, the same premise should pertain to the 1004D. At least I think that is a logical correlation.

Disclosure of "Prior Services" (not prior involvement) is a USPAP requirement, not FNMA.
The 1004D has a signed certification and additional certifications are allowed.

The requirement is:

If known prior to agreeing to perform an assignment, and/or if discovered at any time during the assignment, an appraiser must disclose to the client, and in each subsequent report certification:
• any current or prospective interest in the subject property or parties involved; and
• any services regarding the subject property performed by the appraiser, as an appraiser or in any other capacity, within the three-year period immediately preceding the agreement to perform the assignment.

24. DISCLOSING PRIOR SERVICES WHEN FORMS DO NOT INCLUDE ALL OF THE REQUIRED CERTIFICATION
ELEMENTS
Question: Most of my assignments are completed using common residential appraisal report forms. I am concerned that my clients do not allow changes to the certification on the report forms. The Conduct section of the ETHICS RULE requires that I disclose prior to agreeing to perform the assignment and in the report certification whether prior services were performed regarding the subject property. Does this mean that I will not be allowed to appraise a property for these clients if I have performed a service regarding that property in the previous three years?

Response: USPAP compliance is the appraiser’s responsibility. While deletion or modification of clientimposed certifications may not always be allowed, most clients allow additional certifications that do not constitute material alterations to the appraisal report. In these circumstances, it would be necessary for the appraiser to include a supplemental certification unless and until such forms are revised to comply with the requirements of Standards Rule 2-3(a).

289. USE OF CERTIFICATION WITH FORM 1004D/442 – APPRAISAL UPDATE
Question: My client has asked me to update an appraisal that I completed for them eight months ago and submit the report on the Fannie Mae Form 1004D/Freddie Mac Form 442. Does this assignment require a certification regarding the prior service?

Response: Yes. Because an appraisal update is a new appraisal assignment, regardless of the form used to report the results, the report must include a certification disclosing whether you have provided a service regarding the subject property in the three years prior to agreeing to perform the new assignment. Each real property appraisal report, including those for update assignments, must include
a signed certification that, at a minimum, addresses the items specified in Standards Rule 2-3(a). The certification in the prior report cannot be incorporated by reference, since it would not be possible to have certified in the past that the work done in the present meets all of the requirements to which the appraiser must certify.

268. REVISING APPRAISAL FORM CERTIFICATION TO DISCLOSE PRIOR SERVICES
Question: I perform residential real estate appraisals using “standard” appraisal forms, such as those developed by Fannie Mae. I’ve heard that Fannie Mae does not allow any changes to their certifications, so how can I comply with the USPAP requirement to disclose, in the certification, any prior services I have or have not performed on the property within the prior three years?

Response: Fannie Mae does not prohibit additional certifications to their appraisal forms, as long as those additional certifications do not conflict with or diminish the “standard” certification items appearing on their forms. Therefore, appraisers may create a supplemental certification to comply with the obligations of the Conduct section of the ETHICS RULE as well as the requirements of Standards Rules 2-3(d) and 4-3(d).

 

[Tom4value]

The 1004D already has a line titled "Original Appraiser", so your "prior services" is already disclosed.

Yes, I was about to mention that. It also has the date of the original appraisal.

I am sure hard butts would say that a reader would have to put all the pieces together but.. come on.

 

[ZZGAMAZZ]

Disclosure of "Prior Services" (not prior involvement) is a USPAP requirement, not FNMA.
The 1004D has a signed certification and additional certifications are allowed.

The requirement is:

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Best AF post of all-time. Needs to be a sticky although the topic is very esoteric.

 

[lionfish]

Certification of completions don't have to be completed by an appraiser so is it an appraisal service? Really hope they separate Appraisal Update and Certification of Completion with the new secondary market forms.

 

[DWiley]

Really hope they separate Appraisal Update and Certification of Completion with the new secondary market forms.

That is the plan

 

[ZZGAMAZZ]

Certification of completions don't have to be completed by an appraiser so is it an appraisal service? Really hope they separate Appraisal Update and Certification of Completion with the new secondary market forms.

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But would non-appraiser certifications be reported on a 1004D?