I guess my spin on this is why? I am not going to do a 2055 anyway, but if asked to for new construction, I would simply tell the lender that the form 2055 was not designed to accomodate a cost approach nor (if i recall correctly) plans and specs appraisals. Therefore, the cost of amending the report to comply with USPAP would exceed the cost of doing the report on a form that is considered plans and specs friendly.
If the purpose of the 2055 request is to reduce your fee and you are suffering the cruel pinch of want and will be willing to do so, then I suggest you rethink your marketing strategy.
Yes, I agree that you could use a restricted format, i.e.- Restricted Use Appraisal Report.
And, Std. 2 - 2 c(ii) explicitly states the INTENDED USE of the appraisal must be consistent with the limitations on use of the RUAR (not URAR, but Restricted Use Appraisal Report) option (i.e.-, client use only)." - their words not mine...
Likewise, if this is being sold or going to secondary market lenders, how can the client [lender] be the sole user? If an underwriter can call you, then it went to more than just the lender.
Since mortgage lending involves a report which can be obtained by the borrower, the question is are they an intended or unintended user? No problem unless the borrower feels like the appraisal queered his deal, and the client points at the appraiser on why the loan fell through, and maybe you took the pay at the door.....I don't care what SMT 9 says about borrowers not being intended users, the courts do not have to honor the intent of USPAP.
Maybe you would like to face that in court, I wouldn't. I would not like my odds. So, again. Why charge a subpar fee for a report with above average risk? Do a complete appraisal in a summary format. Forget the restricted nonsense. Restricted reports "fly" only because no one complains. I don't want to bet the ranch on my wordsmithing to circumvent the full reporting options, when in fact, the resulting report likely will take as long or longer than a conventional URAR.
Ter