alex gilbert
Member
- Joined
- Feb 21, 2003
- Professional Status
- Certified Residential Appraiser
- State
- California
Ross,
I agree with you that, in trying to solve some issues, the new 2004 A-Os raised others. I also totally agree with you that this “re-printing” and “re-appraising” between lenders is a major waste of everybody’s time and effort. It is also unnecessary. Per FIRREA, any lender can use an appraisal done for any other lender, provided they do a review. There’s absolutely no requirement that a report done for Lender A show Lender B’s name if B makes the loan. It is common practice in commercial assignments to use reports done for other lenders. I just don’t see why residential lenders don’t follow the same guidelines. It just makes too much sense, I guess.
That being said, Doug’s case is different. He didn’t appraise the property for a lender, but for the seller. FIRREA & FDIC compliance requires the appraisal be ordered by a lender or lender’s agent (like a mortgage broker), not a party to the transaction. This is a case where a new appraisal must performed. It’s up to the lender if they’ll go with the retrospective option or not.
I agree with you that, in trying to solve some issues, the new 2004 A-Os raised others. I also totally agree with you that this “re-printing” and “re-appraising” between lenders is a major waste of everybody’s time and effort. It is also unnecessary. Per FIRREA, any lender can use an appraisal done for any other lender, provided they do a review. There’s absolutely no requirement that a report done for Lender A show Lender B’s name if B makes the loan. It is common practice in commercial assignments to use reports done for other lenders. I just don’t see why residential lenders don’t follow the same guidelines. It just makes too much sense, I guess.
That being said, Doug’s case is different. He didn’t appraise the property for a lender, but for the seller. FIRREA & FDIC compliance requires the appraisal be ordered by a lender or lender’s agent (like a mortgage broker), not a party to the transaction. This is a case where a new appraisal must performed. It’s up to the lender if they’ll go with the retrospective option or not.