Converting from Reverse to Forward FHA

[Don Clark]

I wonder if they would hold that same position if it were a client loan number, and nothing else changed?

Simple. If there is a new assignment number, it is a new assignment. A new assignment, if one follows the guidance of the AO's does not necessarily mean that one must start all over. It usually conveys the message that there will be a new assignment date, perhaps a new date of inspection, and certainly the date of the report would change.

 

[hastalavista]

Simple. If there is a new assignment number, it is a new assignment. A new assignment, if one follows the guidance of the AO's does not necessarily mean that one must start all over. It usually conveys the message that there will be a new assignment date, perhaps a new date of inspection, and certainly the date of the report would change.

I don't see it as simple as you do. :new_smile-l:
Refer to FAQ#159, which deals with changing the SOW after the report has been submitted.
In the OP's case, we have:
A. The same client.
B. The same inspection, valuation analysis, and reporting requirements.
C. The same intended use and users (mortgage finance decision, the client and HUD can rely upon the report.
D. The same borrower and the same property.

The client wants a loan or FHA case number changed. The case number issue is FHA-specific, so if that cannot be changed per them, that's an FHA issue (IMO); and only by extension does it become a USPAP issue.

Why does changing a loan number, when no development fundamentals change, become a new assignment?
I'd say if one can change the SOW after the report is submitted (which is very significant, IMO), I don't see why a loan number cannot be changed.
If reporting the loan number is an "assignment condition", then the SOWR allows for modifications to the assignment conditions as long as results are credible given the intended use.

Obviously (for reasons I don't understand) the OP's regulator sees it different. And you (Don) see it different. I don't see the part where it says an appraiser cannot change the loan number without creating a new assignment. In fact, I see, in cases where the client and intended use do not change, a lot of other things can change without creating a new assignment.

If I were in the OP's situation now, I'd call my regulator and ask them. If they told me it is a new assignment, then I'd follow their advice. But I'd ask them where in the USPAP are they reading that so I could understand how they came to that conclusion.

 

[Don Clark]

I don't see it as simple as you do. :new_smile-l:
Refer to FAQ#159, which deals with changing the SOW after the report has been submitted.
In the OP's case, we have:
A. The same client.
B. The same inspection, valuation analysis, and reporting requirements.
C. The same intended use and users (mortgage finance decision, the client and HUD can rely upon the report.
D. The same borrower and the same property.

The client wants a loan or FHA case number changed. The case number issue is FHA-specific, so if that cannot be changed per them, that's an FHA issue (IMO); and only by extension does it become a USPAP issue.

Why does changing a loan number, when no development fundamentals change, become a new assignment?
I'd say if one can change the SOW after the report is submitted (which is very significant, IMO), I don't see why a loan number cannot be changed.
If reporting the loan number is an "assignment condition", then the SOWR allows for modifications to the assignment conditions as long as results are credible given the intended use.

Obviously (for reasons I don't understand) the OP's regulator sees it different. And you (Don) see it different. I don't see the part where it says an appraiser cannot change the loan number without creating a new assignment. In fact, I see, in cases where the client and intended use do not change, a lot of other things can change without creating a new assignment.

If I were in the OP's situation now, I'd call my regulator and ask them. If they told me it is a new assignment, then I'd follow their advice. But I'd ask them where in the USPAP are they reading that so I could understand how they came to that conclusion.

Simple. Once a report is issued, with a date of the report, and except for correcting minor errors, a new assignment number would require a new date of the report and effect date as everything that happened up to that point would have been in the previous assignment locked in time to an effective date and/or a new date of the report.

 

[hastalavista]

Simple. Once a report is issued, with a date of the report, and except for correcting minor errors, a new assignment number would require a new date of the report and effect date as everything that happened up to that point would have been in the previous assignment locked in time to an effective date and/or a new date of the report.

That doesn't square with the FAQ I cited.
The FAQ I cited states that significant changes to a report can be made after it is submitted that do not trigger a "new assignment" situation.

But, regardless, the OP's board said it is a new assignment, you think it is a new assignment, and if I were in that position (now), I guess I'd be best served to call my regulator to see what they think.

 

[Don Clark]

That doesn't square with the FAQ I cited.
The FAQ I cited states that significant changes to a report can be made after it is submitted that do not trigger a "new assignment" situation.

But, regardless, the OP's board said it is a new assignment, you think it is a new assignment, and if I were in that position (now), I guess I'd be best served to call my regulator to see what they think.

That would be my take on it as well. And, a state regulatory board is the one to decide whether or not something is in accord with USPAP, withing limits of course.

In the OP's case, and many other cases, lenders tend to treat an assignment as an ongoing, never ending and ever changing document to suit their needs, not the appraisers. If one thinks this is bad, wait until the ASB approves "Drafts". There will be no limit on how many, for what, and for what purpose. Sorta like Willy Wonkas everlasting gob stopper, until a client gets exactly what they want. Just another form of coercion.