AIR Appraiser Independence Requirements

[lefty2cox]

I recently have had two mortgage clients request that I sign an "Appraisal Independence Certification" form for each assignment. The form begins...

"I hereby certify that the ordering and delivering of the above referenced appraisal report was completed using policies and procedures in compliance with the Appraiser Independence Requirements (AIR) and the USPAP standards."

This document concerns me and I was wondering if anyone else has been asked and what their thoughts were.

I'm very familiar with the AIR and they appear to be requirements for sellers on the secondary market and not appraisers. The document clearly lays out policies and procedures for sellers and not appraisers. I don't see, as a sub-contractor for a mortgage client, how I would ever know if the ordering of any particular appraisal was in compliance with the AIR. By signing the document, however, I am accepting responsibility.

I am especially interested in comments from those in the legal and E&O professions but welcome comments from all. Please also read the AIR before commenting. The link is below.

https://www.fanniemae.com/content/fact_sheet/appraiser-independence-requirements.pdf

 

[Mike Kennedy]

Appraiser certifies USPAP compliance.

Lenders/3PA certify to Fannie - para VIII

 

[Meandering]

Asking you to include an AIR Certification is a violation of Fannie Mae's AIR and something you can't certify to until you have been paid.

That's what I always put in when they ask me. Your clients are idiots. THE AMC needs to certify to not violating the AIR not you. Look at the air, and then certify that you will pay yourself in a timely manner, not with hold business from yourself, or remove yourself from a list of qualified appraisers.

http://www.orea.ca.gov/pdf/FNMA-AIR.pdf

And they are entitled to an appraisal fee why?????


.

 

[lefty2cox]

Marion,

There is actually no AMC involved here; however, I agree with you wholeheartedly. I just needed to know I wasn't crazy.

This is a concern of mine as I've had two unrelated clients request the almost identical document be signed. Both have resisted my requests to alter the language. The concern is that this is an industry trend and most appraisers will just sign it as most probably haven't read the AIR.

I seem to be the only appraiser on both clients' lists who has pushed back on this. As more and more appraisers roll over, it becomes more difficult to convince and educate mortgage clients.

I hope others read this thread.

 

[Meandering]

Marion,

There is actually no AMC involved here; however, I agree with you wholeheartedly. I just needed to know I wasn't crazy.

This is a concern of mine as I've had two unrelated clients request the almost identical document be signed. Both have resisted my requests to alter the language. The concern is that this is an industry trend and most appraisers will just sign it as most probably haven't read the AIR.

I seem to be the only appraiser on both clients' lists who has pushed back on this. As more and more appraisers roll over, it becomes more difficult to convince and educate mortgage clients.

I hope others read this thread.

Lefty,

I feel your pain, believe me. There are so many Skippy, backside kissers in this industry it's frightening sometimes.

But I do very, very little lender work for residential.

You can sign their silly paper then put in your report you were pressured through coercion to sign their silly paper under the threat of not being paid which is a violation of Fannie and Frank Dodd Air., But, you will lose a client over it.

Me, I don't care if they all walk. I'll sleep better at night.

Do what you can live it, just choose the hills you die on carefully, because some deaths are slow and painful, I just choose the quick and over with so I can move on.


.

 

[sputnam]

You might be crazy... further evaluation would be needed... however, your post isn't crazy. I see a lot of reports that have a similar statement built in to the report. I suspect that a lot of times it's an appraiser who doesn't fully understand trying to cover all possible points of liability. I've sometimes seen reports that have 2 or 3 versions of the same addendum form labeled something like 'USPAP Compliance Addendum'. I guess they can't be bothered to figure out which one is the current version.

 

[lefty2cox]

Sputnam,

If your evaluation includes an interview with my wife, I'm screwed.

 

[Mike Kennedy]

Sputnam,

If your evaluation includes an interview with my wife, I'm screwed.

nah - just be sure to wear yours >>>>>

http://appraisersforum.com/showthread.php?t=199331

 

[offtherecord]

I recently have had two mortgage clients request that I sign an "Appraisal Independence Certification" form for each assignment. The form begins...

"I hereby certify that the ordering and delivering of the above referenced appraisal report was completed using policies and procedures in compliance with the Appraiser Independence Requirements (AIR) and the USPAP standards."

This document concerns me and I was wondering if anyone else has been asked and what their thoughts were.

I'm very familiar with the AIR and they appear to be requirements for sellers on the secondary market and not appraisers. The document clearly lays out policies and procedures for sellers and not appraisers. I don't see, as a sub-contractor for a mortgage client, how I would ever know if the ordering of any particular appraisal was in compliance with the AIR. By signing the document, however, I am accepting responsibility.

I am especially interested in comments from those in the legal and E&O professions but welcome comments from all. Please also read the AIR before commenting. The link is below.

https://www.fanniemae.com/content/fact_sheet/appraiser-independence-requirements.pdf

I suspect what they are trying to convey is that you were not engaged by anyone in loan production and that you were not coerced.

 

[Lost Cause]

I suspect what they are trying to convey is that you were not engaged by anyone in loan production and that you were not coerced.

Many appraisers are in no position to know whether the person who engaged them is in loan production or not.