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Evaluations & USPAP - Question from a bank staff appraiser

I suspect that for non-appraisers doing evaluations no such addressing by TAF or anyone else except the bank laws themselves will matter.

Evals by appraisers are the issue. No appraiser can comply with USPAP and actually compete with the evaluator who charges 2/3rds what an appraiser gets for an appraisal and spends one-third the time preparing it. You very literally can do an evaluation using the cost approach alone. Verification is not required and the lender can provide the proof on 'inspection' with a photograph while the evaluator is not required to visit the property - desktop evaluations. No appraiser can compete and comply with USPAP at the same time.
Idk the demand for evaluations nor the salaries of it as a job - but if it is true that an appraiser can not compete as an appraiser,r then drop the license and call yourself an analyst -
 
Idk the demand for evaluations nor the salaries of it as a job - but if it is true that an appraiser can not compete as an appraiser,r then drop the license and call yourself an analyst -
I had a CG friend do exactly that. He did commercial valuations under the deminimus and told me he got $500 for each report. He made no adjustments simply put in 3-6 comp MLS sheets, ranked them by price and picked a point. He did drive by them and did have access to the MLS since he was a Realtor as well. He could do from 3 to 6 a week...at the time (about 2012) he was only getting 4 or 5 appraisals a month and had it not been for a few sales he made; he would have starved out anyway.
 
Evals by appraisers are the issue. No appraiser can comply with USPAP and actually compete with the evaluator who charges 2/3rds what an appraiser gets for an appraisal and spends one-third the time preparing it. You very literally can do an evaluation using the cost approach alone. Verification is not required and the lender can provide the proof on 'inspection' with a photograph while the evaluator is not required to visit the property - desktop evaluations. No appraiser can compete and comply with USPAP at the same time.
Well - Unless you are an appraiser in Tennessee. Here the law was originally written to literally exempt us, so we could perform evaluations in those instances they could be used. The questions about appraisers doing them in our state have already been investigated, and we have a signed AG conclusion that evaluations are simply not appraisals, nor do those completing them need to comply with appraisal standards. I would submit that one must be cautious in what is said and done in an evaluation to be sure it is not viewed as an appraisal, but there is nobody more qualified to complete an evaluation than an appraiser.

The real problem with evaluations or any other non-appraisal product, comes down to the expanding reasons to use them. In the beginning, they were perfect only for summaries of markets involving a HELOC or mortgages less than 50% LTV. In our state, appraisers could do those very limited market shots and reveal data of pricing ranges applicable for certain groups of properties based on public record information alone. Today, we are stupidly finding all kinds of reasons to bypass a professional appraisal and requiring more specificity than the evaluation was first created for. Have to be careful, but it can legally be done.
 
My question is why there is such resistance to following USPAP? Why the complaints? Is it too confusing? Too much additional work? Unnecessary for credible results and clear reporting? I just don't get it. I can't imagine preparing a report without at the very least those few requirements. Maybe I'm a glutton for punishment.

15th st is a party...ask relman :ROFLMAO:
 
I had a CG friend do exactly that. He did commercial valuations under the deminimus and told me he got $500 for each report. He made no adjustments simply put in 3-6 comp MLS sheets, ranked them by price and picked a point. He did drive by them and did have access to the MLS since he was a Realtor as well. He could do from 3 to 6 a week...at the time (about 2012) he was only getting 4 or 5 appraisals a month and had it not been for a few sales he made; he would have starved out anyway.
There is nothing in USPAP that would prevent an appraiser from doing the same as long as they hot the other high points. I know you think otherwise but you're wrong.

It would take less than 5 minutes to fill out pg 1 of this 2pg report form - the rest being boilerplate. That 5min is not counting what else it would take to augment for an Evaluation. And since the developer of this form was TAF itself neither you nor anyone else can claim it's substandard to the requirements of USPAP proper.

As far as using a CA instead of making an effort to get to an actual opinion of MV, that's a problem alright. But only for people who are attempting to work in good faith instead of lying to their users. And sure, an licensed/certified appraiser is just as capable of telling that lie as anyone else - if that's what they're trying to do.

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Idk the demand for evaluations nor the salaries of it as a job - but if it is true that an appraiser can not compete as an appraiser,r then drop the license and call yourself an analyst -

In Florida, appraisers can complete evaluations without following USPAP. Most lenders will not provide work if you attempt to make evaluations USPAP compliant.
 
Pics or "not provide work" didn't happen; not for treating an appraisal like an appraisal. I actually perform assignments for lenders who use evals and I've never been hassled by one of them for proceeding that way. Nor does it cost me a dime extra to proceed that way.
 
I know you think otherwise but you're wrong.
What bank accepts a restricted report for a loan? They do accept an evaluation.

I took the evaluation vs appraisal class from this guy. RIP Calvin. We miss you.

In 2001 Calvin developed a 40-hr pre-course and a 35-hr classroom course, Real Estate Appraisal Review School (REARS) and began teaching bank examiners for the Federal Financial Institutions Examination Council that continued through 2019. In 2010 he co-developed and then co-taught Distressed Commercial Real Estate through 2019. In addition to these classes taught in Arlington, VA, Calvin also provided the REARS class online for the Conference of State Bank Supervisors. He authored the textbook, Principles of Residential Real Estate Appraising which was used for classroom instruction in many states. A version of the Principles textbook continues to be used by the Canadian National Association of Real Estate Appraisers.​
 
All of my clients that have engaged them have accepted them. Now I have never used the 2-pg TAF form I posted. I've always added more detail. But the ASB has already provided an example of what "summarize" looks like and it's not going to take a 50pg narrative to do it. Nor does "summarize" require the summary to appear in paragraph format.

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You've seen how much original writing there is in a URAR, right? Nor does SR2-2a require adjustment grids or several other extras the GSEs have added into their forms.
 
It would take less than 5 minutes to fill out pg 1 of this 2pg report form
So what? Are you saying that an appraiser can simply fill it out in a vacuum? That they can ignore researching the comps and having sufficient evidence to write a summary report? An evaluation can literally fill out the form with almost nothing, no research, no confirmation, no real analysis. The lender or loan officer can do the photo and inspection. A photo is 'proof' of an inspection.

An evaluation’s content should be documented in the credit file or reproducible. The evaluation should, at a minimum:
Identify the location of the property.
Provide a description of the property and its current and projected use.
• Provide an estimate of the property’s market value in its actual physical condition, use and zoning designation as of the effective date of the evaluation (that is, the date that the analysis was completed), with any limiting conditions.
Describe the method(s) the institution used to confirm the property’s actual physical condition and the extent to which an inspection was performed.
• Describe the analysis that was performed and the supporting information that was used in valuing the property.
• Describe the supplemental information that was considered when using an analytical method or technological tool.
Indicate all source(s) of information used in the analysis, as applicable, to value the property, including:
o External data sources (such as market sales databases and public tax and land records);
o Property-specific data (such as previous sales data for the subject property, tax assessment data, and comparable sales information);
o Evidence of a property inspection;
o Photos of the property;
o Description of the neighborhood; or
o Local market conditions.
 
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