Comp Removal Per Client - USPAP Violation

[shrubberyvaluation]

It would be awesome if there weren't any bozo appraisers out there. Fact is, though, that there are. Still inappropriate to 'force' an appraiser to do anything, though. It's the appraiser's signature. If they're really a bozo appraiser, their state board will know them soon enough anyway.

Its kind of like holding an audit over your head. Do this or you get audited. Even if you have all your t's crossed and I's dotted its still a pain and you don't know if they will make a stupid ruling. So you capitulate or else.

 

[alebrewer]

Its kind of like holding an audit over your head. Do this or you get audited. Even if you have all your t's crossed and I's dotted its still a pain and you don't know if they will make a stupid ruling. So you capitulate or else.

You might be surprised at how bad some appraisals are. No lender that I've ever been associated wants to take the time to submit stuff to the state. Lenders do, however, have mandatory reporting requirements.

 

[TerryRohrer]

Lenders do, however, have mandatory reporting requirements.

Who enforces those?

 

[alebrewer]

Who enforces those?

Most investor and GSE audits will include some level of request for P&P's RE disposition of appraisals with perceived USPAP violations. IRL, not very heavily.

 

[J Grant]

Another appraiser in my market area removed a comparable sale from his report at the insistence of the client. They basically said they wouldn't accept the report with that sale included. The subject property was a somewhat unique property, and the removed sale was several years old (but still a somewhat similar property to the subject). But now in hindsight he is concerned that he shouldn't have removed it. I can't find anything in USPAP addressing this type of situation. Was this a USPAP violation?

Having a client ask to remove a comp with the threat of not accepting the report is called an unacceptable assignment condition.

The word NO exists for a reason.

 

[J Grant]

The test for these decisions is what the other users (as a group) for that assignment would expect and what the other peers performing that assignment would do.

Another part of the test is a client should not be instructing the appraiser in an appraisal (you must add or remove X comp- unless there is a valid reason to do so, like the comp did not actually close or something along those lines ).

 

[glenn walker]

No but they can remove the appraiser from their fee panel......lmao

 

[Tawfik Ahdab]

No but they can remove the appraiser from their fee panel......lmao

Well, it’s either that or the appraiser violating his or her certification of independence.

 

[George Hatch]

Another part of the test is a client should not be instructing the appraiser in an appraisal (you must add or remove X comp- unless there is a valid reason to do so, like the comp did not actually close or something along those lines ).

Actually that isn't part of the test.

 

[George Hatch]

Having a client ask to remove a comp with the threat of not accepting the report is called an unacceptable assignment condition.

The word NO exists for a reason.

It could be an unacceptable condition if there's some indication of dishonesty involved.

Technically what the lender apparently said amounted to "we will not use this appraisal in this form". Meaning that THEY don't think the report meets their development or reporting criteria. Unless they're threatening to not pay or to cut him off they're not actually forcing him to do it.