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3.6 Subject to verse new "Recommended Action"

SunnyDays

Freshman Member
Joined
Jul 25, 2026
Professional Status
Certified Residential Appraiser
State
California
The new 3.6 form uses the term “Recommended Action” for items that will be required to satisfy a “subject to” appraisal. I find this completely misleading!!! If I select repair, or inspection, the item is not simply being recommended, it is required to satisfy the conditions of my report. There is an absolute difference between “recommended” and “required.” And per my understanding, this term would conflict with USPAP based on the misuse of the word "recommended." Heck, even ChatGPT described the terminology as misleading without me first suggesting that conclusion: “The word ‘recommended’ is somewhat misleading. Selecting ‘repair,’ ‘inspection,’ or ‘none’ does not mean you are simply offering optional advice.”

Do Fannie Mae or Freddie Mac not see the problem with using the word “recommended” for something that is required? This simple and misleading box choice could open appraisers up to more liability. There may be items an appraiser would consider recommending for correction but that are not required to be corrected under lender guidelines. A borrower, lender, attorney, or anyone else could later argue that an item labeled “recommended” was optional. Conversely, if “none” is selected for a deferred-maintenance item that does not currently require repair but later results in damage, someone could argue that the appraiser should have 'recommended' its repair. It is beyond reason that Fannie Mae and Freddie Mac would choose such a misleading term for something that is clearly not optional. Do Freddie Mac and Fannie Mae not have a dictionary available? I find this terminology misleading and potentially problematic. A “recommendation” ordinarily suggests an advisory or optional action. A “requirement” is an action that must be completed to satisfy the conditions of the appraisal report. These terms are not interchangeable.

To my fellow appraisers: What additional comments or disclaimers will you be adding to your reports to protect yourself and clearly explain the difference?
 
The new 3.6 form uses the term “Recommended Action” for items that will be required to satisfy a “subject to” appraisal. I find this completely misleading!!! If I select repair, or inspection, the item is not simply being recommended, it is required to satisfy the conditions of my report. There is an absolute difference between “recommended” and “required.” And per my understanding, this term would conflict with USPAP based on the misuse of the word "recommended." Heck, even ChatGPT described the terminology as misleading without me first suggesting that conclusion: “The word ‘recommended’ is somewhat misleading. Selecting ‘repair,’ ‘inspection,’ or ‘none’ does not mean you are simply offering optional advice.”

Do Fannie Mae or Freddie Mac not see the problem with using the word “recommended” for something that is required? This simple and misleading box choice could open appraisers up to more liability. There may be items an appraiser would consider recommending for correction but that are not required to be corrected under lender guidelines. A borrower, lender, attorney, or anyone else could later argue that an item labeled “recommended” was optional. Conversely, if “none” is selected for a deferred-maintenance item that does not currently require repair but later results in damage, someone could argue that the appraiser should have 'recommended' its repair. It is beyond reason that Fannie Mae and Freddie Mac would choose such a misleading term for something that is clearly not optional. Do Freddie Mac and Fannie Mae not have a dictionary available? I find this terminology misleading and potentially problematic. A “recommendation” ordinarily suggests an advisory or optional action. A “requirement” is an action that must be completed to satisfy the conditions of the appraisal report. These terms are not interchangeable.

To my fellow appraisers: What additional comments or disclaimers will you be adding to your reports to protect yourself and clearly explain the difference?
None for me.

If it is subject to repair or inspection, then it is subject to. The pre printed verbiage is not my concern.
 
I wonder if any of the beta tester appraisers out there for the 3.6 have tried to get through a report without triggering drop-down menus.... a shortcut, a hack, just to get through the damn thing.

It certainly doesn't sound like appraising to me.
 
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