Did An Inspection As A Registered Trainee, Lender Claiming No Knowledge

[Bob Ipock]

Hi

Any help would be appreciated. I recently inspected a pretty easy measurable property for a 1004+1007 (refinance). This was for a lender I will not disclose. I informed the lender before that I a NC Registered Trainee wanted and could competently do the inspection of the property and asked if they would be okay with that, since it is more a matter of the lender guidelines than anything. They replied that they just did not want a Trainee signing the report. Now up until this point, for any reports me and my supervisor do, that I personally do the inspection for without him being there, I sign on the left of the report. Then he goes over it and signs as supervising appraiser, checking necessary boxes. The thought was that if I did the inspection I absolutely must sign.
It sounds like according the NCAB actually it is up the the lender guidelines but by signing the 1004 report on the left hand side you are indicating you inspected the property. Right.? If lenders don't want trainees to sign they are basically also saying they don't want a trainee to do the inspection alone. Thanks for the help.

I own the appraisal business that my supervisor is under as the certified appraiser. All checks come to that company and then are split. Hope that makes sense.

The NCAB does NOT allow a trainee to own an appraisal business and EMPLOY a supervisor. Someone has given you some bad information.



21 NCAC 57A .0407 SUPERVISION OF TRAINEES

(a) A certified real estate appraiser may engage a registered trainee to assist in the performance of real estate appraisals, provided that the appraiser:

(1) has been certified for at least three years;

(2) has the number of trainees working under him or her at any one time as follows:

(A) a certified residential appraiser may have two trainees working under his or her supervision at any one time. Once at least one of those trainees has completed 50 percent of the required appraisal experience as set forth in G.S. 93E-1-6, a certified residential appraiser may add another trainee; and

(B) a certified general appraiser may have three trainees working under his or her supervision.

(3) prior to the date any trainee begins performing appraisals under his or her supervision, the supervisor shall inform the Board of the name of the trainee by filing a Supervisor Declaration Form with the Board. The form may be found on the Board's website at www.ncappraisalboard.org. The supervisor shall also inform the Board when a trainee is no longer working under his or her supervision by using the Supervisor Declaration Form. The form shall include the following information:

(A) the name and registration number of trainee;

(B) the name and certification number of supervisor;

(C) the date the trainee completed the supervisor/trainee course;

(D) the date the supervisor completed the supervisor/trainee course;

(E) whether the supervisor has had any disciplinary action within the past three years or pending complaints against his or her certification; and

(F) the signature of both the supervisor and trainee (only required for association).

(4) actively and personally supervises the trainee on all appraisal reports and appraisal related activities until the trainee is no longer under his or her supervision;

(5) reviews all appraisal reports and supporting data used in connection with appraisals in which the services of a trainee is utilized, and assures that research of general and specific data has been conducted and reported, application of appraisal principles and methodologies has been applied,

and that any analysis, opinions, or conclusions are developed and reported so that the appraisal report is not misleading;

(6) complies with all provisions of Rule .0405 of this Section regarding appraisal reports;

(7) reviews and signs the trainee's log of appraisals prepared in accordance with Paragraph (c) of this Rule. The supervisor shall make available to the trainee a copy of every appraisal report where the trainee performs more than 75 percent of the work on the appraisal; and

(8) has not received any disciplinary action against his or her appraisal certificate from the State of North Carolina or any other state within the previous three years. For the purposes of this Subparagraph, "disciplinary action" means an active suspension, a downgrade of a credential, a revocation, or any other action that restricts a supervisor's ability to engage in appraisal practice.

(b) "Active and personal supervision" includes direction, guidance, and support from the supervisor. The supervising appraiser shall have input into and knowledge of the appraisal report prior to its completion, and shall make any changes to the report before it is transmitted to the client. In addition, the supervisor shall accompany the trainee on the inspections of the subject property on the first 50 appraisal assignments or the first 1500 hours of experience, whichever comes first, for which the trainee will perform more than 75 percent of the work. After that point, the trainee may perform the inspections without the presence of the supervisor provided that the supervisor is satisfied that the trainee is competent to perform those inspections, and that the subject property is less than 50 miles from the supervisor's primary business location. The supervisor shall accompany the trainee on all inspections of subject properties that are located more than 50 miles from the supervisor's primary business location.

(c) An appraisal experience log shall be maintained jointly by the supervisor and the trainee. Both the supervisor and the trainee are responsible for maintaining the experience log and ensuring that it is accurate, current, and includes the following:

(1) the type of property appraised;

(2) the type of appraisal performed;

(3) the date the report was signed;

(4) the complete street address of appraised property;

(5) a description of the work performed by the trainee;

(6) the scope of review and supervision of the supervisor, including whether the supervisor accompanied the trainee on the inspection of the subject property;

(7) the number of actual work hours by the trainee on the assignment; and

(8) the signature and state certification number of the supervisor.

The log shall be updated at least every 30 days. A separate log shall be maintained for each supervising appraiser. A log form is available on the Board's website at www.ncappraisalboard.org.

(d) An appraiser shall attend an education program regarding the role of a supervisor before any supervision of a trainee. This course shall be taught only by instructors approved by the Board in accordance with 21 NCAC 57B .0614.

(e) Trainees shall ensure that the Appraisal Board has received the Supervisor Declaration Form on or before the day the trainee begins assisting the supervising appraiser by contacting the Board by telephone or email at ncab@ncab.org. The form may be found on the Board's website at www.ncappraisalboard.org. Trainees shall not receive appraisal experience credit for appraisals performed in violation of this Paragraph.

(f) Supervising appraisers shall not be employed by a trainee or by a company, firm, or partnership in which the trainee has a controlling interest.

(g) If a trainee signs an appraisal report or provides assistance in the appraisal process and is noted in the report as having provided assistance, the appraiser signing the report shall have notified the Appraisal Board before the appraisal is signed that he or she is the supervisor for the trainee. If more than one appraiser signs the report, the appraiser with the highest level of credential shall be the declared supervisor for the trainee. If all appraisers signing the report have the same level of credential, at least one of them shall be declared as the trainee's supervisor before the report is signed.

(h) Only one trainee may receive credit for providing real property appraisal assistance on an appraisal report.

History Note: Authority G.S. 93E-1-6.1; 93E-1-10; 93E-1-12;

Eff. July 1, 1994;

Amended Eff. January 1, 2015; July 1, 2014; January 1, 2013; July 1, 2010; September 1, 2008; January 1, 2008; March 1, 2007; March 1, 2006; July 1, 2005; August 1, 2002; April 1, 1999;

Pursuant to G.S. 150B-21.3A, rule is necessary without substantive public interest Eff. October 3, 2017;

 

[sputnam]

The answers are in USPAP.

 

[Bob Ipock]

What answers are in USPAP?

 

[Tom D]

some long time back a lot of the larger lenders/banks did not want a trainee, of whatever quality, to be involved in the appraisal. another cert appraiser could do the inspection. but the main appraiser had to sign the appraisal also. i guess they didn't think a trainee was qualified. so then, they obviously did not want to see you, or your signature, on any part of the report. but a supervisor has to mention you if you did do any part, and mention what you did. at least in our state you would not get credit without that info and your signature. and the supervisor would get into big trouble if you actually were involved, but not mentioned.
the answer to your question is yes, the lender wants the supervisor appraiser to also do the inspection. they would then allow you to be on the report as a trainee, as aiding the appraiser.