Unless I, an employee, or an appraiser I know and trust has appraised the house very recently, I don't know how I can feel comfortable with the requirement of the certification to verify the information about the subject from a disinterested source. An MLS brief certainly isn't something put together from a disinterested source (though it could be argued that, if the current transaction isn't related to the property's listing, the brief might be considered from a "disinterested" source). If it's a refinance, the homeowner certainly isn't disinterested; if it's a sale, the broker isn't disinterested.
The way the 2055 is put together convinced me that the builders of the report form have only the loosest connection with the realities of the way appraisers go about their business. Yeah, yeah, they want to make appraisers accountable for their reports - I think that's a noble undertaking. But I don't think that can be accomplished by putting appraisers in the position of trying to manage requirements that are, on their face, contradictory. Few appraisers who are concerned about the quality of their work product and who understand the ramifications of those contradictions are going to undertake these assignments. The appraisers who do take them would appear to have rationalized these conflicting requirements or are playing the fool's game of accomodating their lender clients and hoping to get paid enough for these appraisals that the risk is compensated.
And, that this is taking place in an environment when Fannie is offering delivery options for properties for which no appraisal was done.........
