Do you have to sign your appraisal or appraisal review?

[Oregon Doug]

Can someone out there point me to the specific USPAP chapter/verse and line that specifically states that an appraiser must actually sign an appraisal report or an appraisal review or afix his/her name to the report at all?

I have recently seen an unsigned appraisal and an unsigned appraisal review. If you can not determine who the report author is, do you know that it was even completed by a licensed/certified appraiser?

Are you seeing these stealth appraisals & reviews in your corner of the country? Is this a serious issue?

What say you USPAP gurus?

Thanx for your comments, Oregon Doug

 

[rtubbs]

Oregon Doug, see Standards Rule 2-3 which states that "Each written real property appraisal report must contain a signed certification that is similar in content to the following form..." Rule 3-2(f) contains the same requirement.

 

[Don Clark]

Note that it states "signed certification". This has been addressed by several FAQ's(sorry, it's too early & I am too lazy to look up the particular one). The FAQ's make it clear that, althought the report does not require a signature, there must be a signed certification. Also, your state probably requires that you sign the report. Some states not only require you to sign the report, they also require a seal similar to a notary seal. Virginini dropped that requirement several years ago although can still use the seal if you want. North Carolina still requires it. In addition, VA, FHA, Fannie Mae and Freddie Mac require that you sign the report. With all thjs, it would seem that the question is rather moot.

8) Don

 

[Oregon Doug]

Don - you would think that it's a moot question given the requirement for a signature on the Certification page and my state (OR) follows suite in our rules.

I am seeing reports being submitted and USED that are unsigned and there is NO certification page! Of course, we all know that no one is supposed to rely on an appraisal/review that has no Certification page, but they are.

This opens a whole new issue: An appraisal/review without a signed Certification page is a violation of USPAP but if that appraisal/review report without the Certification page is unsigned - the identy of the appraiser/reviewer is unknown - so, who is in violation of USPAP. How do you identify the phantom appraiser? Was the report actually completed by a licensed/certified appraiser?

Just to make it more interesting, lets cross state lines. An appraiser completes an appraisal in state A but the appraisal review (desk review) is completed by an appraiser in state B. The review appraiser (in state B) is not licensed/certified in state A. Has the reviewer performed "unlicensed appraisal activity" in state A? Which state has authority over the appraiser? The state in which the real estate being appraised is located (I think so) or the state in which the appraiser is licensed. (Don, does the state of MI care what you do in OH?) If there was no signed Certification, then I think that the USPAP violation ocurred in the appraiser's home state (B). How do you identify the appraiser without the requirement of a signature on the report itself?

So far, I've only seen a limited number of these stealth appraisals/reviews and I don't know if it is a serious issue or not. Would this apply to AVM's?

I'm just trying to get a little feedback from around the country before presenting this issue at our next board meeting on Apr/26.

Comments/opinions please, Thanx

Oregon Doug

 

[Randy Beigh]

Doug

I need some clarification.

Are you saying that people are doing appraisals and reviews with no signatures or certifications? Or are you saying that appraisals are showing up with the signatures crossed off or blocked out?

I have never seen the former, but the latter happens all the time and there is nothing wrong with that. I can do a review without knowing who did it.

I would think that an appraisal without any signatures or certifications would have all the credibility of a Bill Clinton telling us he didn't inhale.

 

[Oregon Doug]

Randy - I'm saying that people (appraisers?) are doing appraisals and reviews with no signatures or certifications. Do you see these stealth appraisals/reviews as an issue?

How would you deal with a fradulant appraisal if you could not identify the appraiser?

Oregon Doug

 

[rtubbs]

Doug, submit them to your state's appraisal board. Even tho unsigned, there would be ways to trace back to the appraiser that did them. Wow, man, I've never heard of this.

I'm getting appraisals kicked back because NW, SW, etc., is not in the right location in the street address. How can any lender/uw allow a loan to be made on an unsigned appraisal? Of course, we both know the answer to that.

 

[Bemis Pownall]

I was recently given a page 2 with no signature
Looked as if the Realtor had done it. My value was "low" and this grid was done with sales over 5 miles across an interstate and major thoroughfare, I woulnt sign it either.
I told them tanks but I can find and adjust my own comps.

I recently faxed a copy(page 1 & 2)(unsigned, opps) of report for a sale so they could "renegotiate". Ill never do that again, full report with all addenda and cert or nuthin! Try to do a friend a favor..
They ended up paying 15% over a clone sale from Oct.. They really wanted the house, FSBO's appraiser hit value. oh well live and learn.

 

[Pamela Crowley (Florida)]

This sounds like someone's brilliant idea of getting AVM data 'signed off' on by a real appraiser..... for the liability to be put on to an appraiser for a cheaper fee.

Can't think of a better reason that a review appraisal should cost more than a regular appraisal. Any of you doing reviews for less should really think again!!!!

 

[Don Clark]

Doug:

I agree with all the posters. Also, my biggest problem is not that reports are unsigned, it is that the report that is faxed to me is such poor quality that I sometimes cannot read it. In that case I either decline the report or have them send me a legible copy. Now, as to the violation re crossing state lines. Review appraisers around the country are performing reviews of appraisals in jurisdictions not only where they lack competence but also where there are not licened. I would suggest sending a copy of the report, a copy of the review, and a formal complaint to the state where the appraisal was performed and also where the review appraiser is licensed. As to lack of signed certification page, lenders often send incomplete reports to be reviewed. Call them and tell them you need a complete copy of the report. I do not see this problem going away until either the states where the appraisals are performed crack down on out of state reviewers or we go to a federal license. Personally, I would like to see a federal license. As an example, in my state of Virginia we do not have reciprocity with our neighbor North Carolina. However, I am state certified in North Carolina by examination. Since I am certified in North Carolina by examination, I can now apply for a reciprical license in California if I want to. That is just plain stupid. We should have a federal license, be able to register in every state, and do business in a jurisdiction only if we are competent to do so as outlined in USPAP. Sorry, I wax verbose this AM. I am a firm believer in reporting incompetent people to the state. However, don't always expect them to leap for joy when you do so.

Don :twisted: