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2055 & USPAP

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Let's walk this one through...

1. First, the client is ordering an exterior drive-by. The presumption (we all agree) is that the client knows the appraiser is not going to view the interior.
2. The appraiser should check what data sources are available and typically considered by his/her peers in the normal course of business. In my market, that would be MLS and a review to see if the jurisdiction where the subject is located has its permit history on-line. In my case, many do have their permits on-line.
3. The appraiser cites the sources he/she used to research the subject property and then drives by the property.
4. The appraiser notes, based on what is visible from the street, how the exterior of the subject appears.

So, the above is effectively the condition-verification process, right?
What is a reasonable condition determination based on what that data indicates?
It depends.. if there were permits for an interior remodel, does the appraiser have the ability to state that the interior has been remodeled?
I'd say so. However, an appraiser might want to stop the assignment and tell the client, "you know, based on my research, this property has recently been remodeled, but you cannot tell that from the street. Given that the level of finish and quality of materials can be significant, I recommend we upgrade the assignment to an interior inspection."
That would be reasonable, no? (that's what I'd do if this was for new credit, an extension of credit, or a renewal of credit)

What if the home looks typical for the area (and typical equates to C4), and there is nothing to contradict this in the research?
Then, citing the steps taken and the rating concluded sounds reasonable to me, no?

What if the home looks bad on the outside?
The simplest of all situations: given what is observed, an exterior inspection is not appropriate and a request for it to be upgraded to an interior inspection should be made.

Credible results are based on the clients intended use and it presumes that the SOW developed is sufficient to achieve credible results.
The client has ordered an exterior drive-by: so from the get-go they know the interior is not going to be inspected.
If the appraiser discovers something which may lead him or her to believe that the interior condition's visual inspection is necessary to conclude credible results... in other words, something was discovered that changes reliability of an exterior drive-by from "presumed reliable based on due diligence research" to "not reliable based on what we've discovered or observed"... then stop the assignment. The drive-by SOW isn't consistent (reliable) given the intended use and the limtied scope based on what has been discovered.

But in the absence of any contradiction, as long as sufficient due diligence is done, then rate the property based on what the research and observation confirm, cite the steps taken to research the condition, conclude the condition rating, and move on.

What is obvious from my advice is this: Not all properties are going to meet Dens' exterior-only inspection criteria. That's fine.
It is those properties that I think I may need an EA that are the ones that don't meet the exterior-criteria only.
And that would pretty much be my working rule: If I think I need to use an EA for a condition-rating on a drive-by, then I shouldn't be doing this assignment as a drive-by.

:new_smile-l:


By the way, I differentiate the reasonableness of drive-bys based on intended use: origination, extension, or renewal of credit has a higher threshold (for me) than a pre-foreclosure or asset valuation assignment; in those cases, interior access may not be possible, but the client has a legitimate need for a value.
 
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Let's walk this one through...

1. First, the client is ordering an exterior drive-by. The presumption (we all agree) is that the client knows the appraiser is not going to view the interior.
2. The appraiser should check what data sources are available and typically considered by his/her peers in the normal course of business. In my market, that would be MLS and a review to see if the jurisdiction where the subject is located has its permit history on-line. In my case, many do have their permits on-line.
3. The appraiser cites the sources he/she used to research the subject property and then drives by the property.
4. The appraiser notes, based on what is visible from the street, how the exterior of the subject appears.

So, the above is effectively the condition-verification process, right?
What is a reasonable condition determination based on what that data indicates?
It depends.. if there were permits for an interior remodel, does the appraiser have the ability to state that the interior has been remodeled?
I'd say so. However, an appraiser might want to stop the assignment and tell the client, "you know, based on my research, this property has recently been remodeled, but you cannot tell that from the street. Given that the level of finish and quality of materials can be significant, I recommend we upgrade the assignment to an interior inspection."
That would be reasonable, no? (that's what I'd do if this was for new credit, an extension of credit, or a renewal of credit)

What if the home looks typical for the area (and typical equates to C4), and there is nothing to contradict this in the research?
Then, citing the steps taken and the rating concluded sounds reasonable to me, no?

What if the home looks bad on the outside?
The simplest of all situations: given what is observed, an exterior inspection is not appropriate and a request for it to be upgraded to an interior inspection should be made.

Credible results are based on the clients intended use and it presumes that the SOW developed is sufficient to achieve credible results.
The client has ordered an exterior drive-by: so from the get-go they know the interior is not going to be inspected.
If the appraiser discovers something which may lead him or her to believe that the interior condition's visual inspection is necessary to conclude credible results... in other words, something was discovered that changes reliability of an exterior drive-by from "presumed reliable based on due diligence research" to "not reliable based on what we've discovered or observed"... then stop the assignment. The drive-by SOW isn't consistent (reliable) given the intended use and the limtied scope based on what has been discovered.

But in the absence of any contradiction, as long as sufficient due diligence is done, then rate the property based on what the research and observation confirm, cite the steps taken to research the condition, conclude the condition rating, and move on.

What is obvious from my advice is this: Not all properties are going to meet Dens' exterior-only inspection criteria. That's fine.
It is those properties that I think I may need an EA that are the ones that don't meet the exterior-criteria only.
And that would pretty much be my working rule: If I think I need to use an EA for a condition-rating on a drive-by, then I shouldn't be doing this assignment as a drive-by.

:new_smile-l:


By the way, I differentiate the reasonableness of drive-bys based on intended use: origination, extension, or renewal of credit has a higher threshold (for me) than a pre-foreclosure or asset valuation assignment; in those cases, interior access may not be possible, but the client has a legitimate need for a value.

What your saying totally makes sense to me. However, even doing everything you said, there is still assumption involved to give the subject a condition rating. No where in the form does it state the interior is presumed to be in average condition.
 
Then you misunderstood what I am saying, or I was unclear in what I was saying.

Let me try to rephrase: the form or assingnment does not default to a particular condition rating.
The research that is consist with the scope of work determines what the condition rating is.
If there is conflicting data that cannot be reconciled without relying on an EA to resolve, then I argue that the drive-by SOW is inapropriate for the intended use of making a lending decision.
The use of an EA for condition rating is inaproprite for an as-is appraisal*. If one determines one cannot conclude a reliable/credible value without its use, one should conclude that the drive-by SOW is inadequate and request a change of scope (interior inspection).
Or, I suppose, one could use one of the available EA choices in the pre-printed check-boxes and state the value is subject-to the client confirming the condition rating (which means an interior inspecton).

Again, it seems a simple choice to me: either I have enough data doing the drive-by to make a confident condition rating given the SOW or I don't. If I don't, then the drive-by is not the way to complete the assaignment.
:)

* I'm talking GSE lending work where the use of EAs is limited. In the non-GSE world, EAs for as-is appraisals are used all the time.
 
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Oi !

Ok. So I called the state board. From what I gather from the conversation, you can do an as-is appraisal based upon an extra-ordinary assumption checking the as-is box so long as you disclose it accoridngly. He said Fannie Mae cannot expect you (and will not), to complete a form that is based upon only an exterior inspection, and hold you accountable for the interior condition when clearly the form says EXTERIOR ONLY written all over it(every page). I will be including a statement such as:

"The value in this as-is report, is based upon an extra-ordinary assumption that the data relied upon is correct, and that interior of the property is in average marketable condition. No items were noted from the street which would require repairs and none are assumed to exist. If information is discovered to the contrary, value could be impacted, either positively or negatively.

I then would include the definition of an EA.

Ultimately though, one must remember this is an "EXTERIOR" inspection only, and some assumptions must be and can be made.

Oh really?

http://oregonaclb.org/pdf/Spring2008Newsletter.pdf

Proceed to page 10 and read the article by your board.... when you get to this part....

Addendums contravening the scope of work, intended use, and intended user do not work because the scope of work description states “Modifications, additions, or deletions to the intended use, intended user…….are not permitted.” You’re trapped!
My bold and underline for affect. Please, call that person back up and ask them when it was that the ACLB published that they have rescinded their comments they made in their 2008 publication regarding contravening Fannie year 2005 version form SoW via addendum? True the article regards using 2005 forms for non-lender work. However, the contravening of the SoW statements in ANY of the Fannie 2005 forms is still contravening them. I'd enjoy hearing how it is totally peachy in one case but forbidden in another.

:new_popcornsmiley:

P.S. Ask if you can record the phone call or if this person wants to explain that in writing. Also, it would be interesting to find out when it was Fannie notified them about her expectations in this regard, what she will and will not do when it comes to holding appraisers responsible for different things, or was that just a personal opinion?
 
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It requires the same level of information that one uses for the comparables.

The difference is that with the comps, you are going by the condition of a prior closed date of that property, in which the listing will reflect.
Whereas the prior listing of the subject is not reflective of the effective date...it's of a prior date of that listing. Big difference.
 
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Oh really?

[URL]http://oregonaclb.org/pdf/Spring2008Newsletter.pdf[/URL]

Proceed to page 10 and read the article by your board.... when you get to this part....

My bold and underline for affect. Please, call that person back up and ask them when it was that the ACLB published that they have rescinded their comments they made in their 2008 publication regarding contravening Fannie year 2005 version form SoW via addendum? True the article regards using 2005 forms for non-lender work. However, the contravening of the SoW statements in ANY of the Fannie 2005 forms is still contravening them. I'd enjoy hearing how it is totally peachy in one case but forbidden in another.

:new_popcornsmiley:

P.S. Ask if you can record the phone call or if this person wants to explain that in writing. Also, it would be interesting to find out when it was Fannie notified them about her expectations in this regard, what she will and will not do when it comes to holding appraisers responsible for different things, or was that just a personal opinion?

While what they are saying makes some sense, if the form had the power, but I don't agree that it does. The appraiser decides who the client/intended user is. And if the appraiser and who he intends that form to be for understands that, then the form is of no consequence.

In USPAP, the appraiser has to identify the intended users. But in doing that, he must know the definition of an intended user. They are the folks that the appraiser, intend. There is only ONE way to become an intended user - and that is to be identified by the appraiser as an intended user in the report.
 
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Webbed. An EA regarding condition could be viewed as additional clarification of SALC#4 on the form coupled with the assignment being exteiror only with all parties being aware no interior inspection has been done.

Regardless of how recent information one obtains from MLS, Pub Records, there could be a meth lab inside. There could be termite. There could be no walls. What you are saying is that in no way should a 2055 ever be used?
 
And, having done all that, read the Scope of Work and Cert. 10 that are part and parcel of the 2055 report. You can't EA away what those two items require you to do.

RE #10: If you don't speak to the homeowner, what do you have to verify from a disinterested source?
 
RE #10: If you don't speak to the homeowner, what do you have to verify from a disinterested source?


Therein lies the rub. I don't think the homeowner fits into what is contemplated by "a disinterested source" . Which, to my admittedly provincial way of thinking, means that if you can't find a reasonably (and reasonably current) source of data from some disinterested source, you aren't complying with the current form 2055's scope of work, nor can you EA that scope away.

I tend to think that such assignments are not acceptable, and I don't do them. If a client will accept some other scope of work/limiting conditions/certifications, I will do them, but not on the current GSE forms.
 
If this is for mortgage finance... the EA of regarding the interior (similar to the interior of the walls with a 1004) has already been taken care with the scope of work on the pre-printed form. If you were unable to provide a credible report without more knowledge of the interior, the appraiser is to turn down the assignment.


don-quixote.jpg


I fail to see how one can create a credible report without seeing the interior. Regardless of a recent MLS listings, how do you know the roof didn't spring a leak a few days before the effective date of the appraisal and there is mold and mush everywhere?

If that's the case, why would they create a 2055 form that under no circumstance could be done without an EA?
 
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