Res-
I happen to know Rich personally and consider him a
peer in the technical-USPAP sense; that is to say, someone who is competent and has the experience in the appraisal issue he is dealing with. I am not his peer as he has likely forgotten more than I know. I happen to consider him a friend, so I have a bias here (so weigh my comments with that in mind).
I believe that Rich's intent and objective in writing articles and developing courses in regards to residential mortgage appraisals and the Fannie/Freddie forms and guidelines is based on his sincere desire to give back to the appraisal community.
In every presentation of Rich's (or his partner's) that I've attended regarding Fannie, 1004mc, etc., the vast majority of the participants start the class by saying how they don't like the form, don't like UAD, don't like CU, etc., etc. (Hell, I don't like it either). Rich will sit there, listen for a bit, and say something like,
"I hear you. This presentation isn't designed to defend what they are doing and it doesn't matter whether I, you, or the guy next door likes it or doesn't like it. This presentation is designed to inform you of what the expectation is and how the form/process/guideline works. So, at the end of this presentation, you will know how to do what they are asking you to do."
That is what Rich is doing (IMO) with his articles, etc. He has gone to the powers that be, found out what they expect, and has tried to communicate that to appraisers who are still confused as to how to fill out a stupid form.
And in regards to the 1004mc, we can supplement it to our hearts content, so if we think it by itself may be misleading, I don't see how we can still think that if we supplement it and draw our conclusions (and explaining such in the report) based on our supplemental analysis.
In the four-hour Residential Cost Approach class I teach, I get death stares when I tell the participants that if you are not supplementing your site valuation estimate with hard data that cannot be replicated, you are not completing the assignment correctly per the expectations and you leave yourself open to an easy "gotcha" by a state regulatory agency. Then I demonstrate three methods that can be applied under any scenario and I emphasize "any". There is usually a component in the class that says, "that's way too much work... you are nuts... there is no data.... that isn't reliable....we don't get paid enough...[and my favorite]..no one uses the cost approach anyway."
When the dust settles, I say, "I hear you. I'm just providing you the techniques and examples of how you can complete the assignment and never worry about not meeting expectations. Whether you want to do it or not, I'll leave to you."
(and, trust me, I'm not getting rich teaching courses. I don't do it for the money, and that is fact).
Rich didn't develop the 1004mc form. But Rich knows what the expectations are by those who did develop it and Rich is simply informing appraisers what those expectations are to enable them to correctly complete the form. There is no hidden agenda here. But there is worthwhile information here.
Finally, the reason I'm jumping in and sticking my nose into this is because I just don't like to see two forumites, who I like, have spoken with, and respect, argue about something where I don't really understand what there is to argue about.
One guy's opinion of the 1004mc reflects the vast majority of appraisers: The form sucks.
The other guy is simply providing information on how the form, as suckee as it is, is expected to be filled out.
What's the argument about?