Ben Vukicevich SRA
Senior Member
- Joined
- Feb 9, 2002
- Professional Status
- Certified General Appraiser
- State
- New Jersey
Fred,
Yikes!!! Lot's of questions. Here's my takeopinion on the matter.
First read this post by Rstrahan
http://appraisersforum.com/forums/viewtopic.php?t=1489
That will take care of most of your concerns or maybe even confuse you some more. Nothing seems to be clear on the appraisers end of things. This stuff is all written to benefit the banks/lenders.
So 1) No, it is not a federally related transaction because the loan is underwritten to FNMA guidelines and can be sold to FNMA, even if they hold it in portfolio and never sell it.
2) A mortgage broker is not a depository institution under FDIC, OTS,OTC,
etc so it is not an FRT. And if the loan was going to a regulated institution, then it would have to be prepared in their name, not the brokers, which would alert you to that fact. Once again, the loan conforms to FNMA guidelines so as in 1 above, it's not an FRT
3) An AMC is not a depository institution plus you stated the loan would conform to FNMA guidelines again, so even if the AMC's client is a regulated depository institution, it's not an FRT.
4)Is a strange one. I would assume that you are refering to a narrative residential appraisal?. Maybe a jumbo loan over FNMA limits? If it's a narrative and not eligible for sale to FNMA, then it would be under the agencies guidelines and it would be an FRT and you would have to complete an "as-is" value as per Statement 10 in USPAP.
All of this can be solved by a proper engagement letter from the client as to what they require or a review of the regulated institution's appraisal guidelines but too often in the residential field, we fail to get them.
I hope I helped somewhat and I would appreciate your additional input on my interpretations of your questions.
Ben
Yikes!!! Lot's of questions. Here's my takeopinion on the matter.
First read this post by Rstrahan
http://appraisersforum.com/forums/viewtopic.php?t=1489
That will take care of most of your concerns or maybe even confuse you some more. Nothing seems to be clear on the appraisers end of things. This stuff is all written to benefit the banks/lenders.
So 1) No, it is not a federally related transaction because the loan is underwritten to FNMA guidelines and can be sold to FNMA, even if they hold it in portfolio and never sell it.
2) A mortgage broker is not a depository institution under FDIC, OTS,OTC,
etc so it is not an FRT. And if the loan was going to a regulated institution, then it would have to be prepared in their name, not the brokers, which would alert you to that fact. Once again, the loan conforms to FNMA guidelines so as in 1 above, it's not an FRT
3) An AMC is not a depository institution plus you stated the loan would conform to FNMA guidelines again, so even if the AMC's client is a regulated depository institution, it's not an FRT.
4)Is a strange one. I would assume that you are refering to a narrative residential appraisal?. Maybe a jumbo loan over FNMA limits? If it's a narrative and not eligible for sale to FNMA, then it would be under the agencies guidelines and it would be an FRT and you would have to complete an "as-is" value as per Statement 10 in USPAP.
All of this can be solved by a proper engagement letter from the client as to what they require or a review of the regulated institution's appraisal guidelines but too often in the residential field, we fail to get them.
I hope I helped somewhat and I would appreciate your additional input on my interpretations of your questions.
Ben