Evaluations & USPAP - Question from a bank staff appraiser

[Terrel L. Shields]

Do evaluations completed by an appraiser, who is an employee of a bank need to conform to USPAP?

I am not aware of any law that requires an EMPLOYEE of a bank to conform to USPAP within the scope of the evaluations as an EMPLOYEE. HOWEVER, it would not be difficult to create a template that meets all the touchstones of the AIG requirements for evaluations while meeting the requirements of a restricted appraisal report.

But since this can be a state-by-state case, I would contact the board and see what they say.

 

[J Grant]

I am not aware of any law that requires an EMPLOYEE of a bank to conform to USPAP within the scope of the evaluations as an EMPLOYEE. HOWEVER, it would not be difficult to create a template that meets all the touchstones of the AIG requirements for evaluations while meeting the requirements of a restricted appraisal report.

But since this can be a state-by-state case, I would contact the board and see what they say.

If the employee is an appraiser and that person gives an opinion of value, they are dating in the capacity of an appraiser and giving an opinion and this it should be a USPAP compliant report -idk what the reason for not doing it is - it might add five minutes in time?

 

[J Grant]

Clients or users like to label valuations a certain way -usually to avoid paying more for them. They might call it a short-form report, an evaluation, and so on.

Does not matter what THEY call it - if an appraiser offers an opinion of value it is an appraisal and should be USPAP compliant.

 

[chad hampton]

Have to love a profession where there’s a half dozen names for the same thing. With the sole purpose to skirt rules, regulations, licensing, etc.

 

[J Grant]

Have to love a profession where there’s a half dozen names for the same thing. With the sole purpose to skirt rules, regulations, licensing, etc.

The purpose is to skirt regulations, pay less, and make more money for the user or third-party middleman.

The clients on some of these products say it takes 45 minutes, and they pay $50 -$75/. . I can not get a lawn guy to show up for $50. Even a short-form desktop takes 3 hours or more—unless one just data dumps and signs, which is what the profiteers want, so they can pad the bill three times to their customers.

 

[Mark K]

If it looks like a duck, walks like a duck, quacks like a duck, its either a duck... or just a bird.

I'd like to see what happens when someone goes duck hunting without a license but when they get caught by the DNR, they can simply call it a generic bird and not be prosecuted.

 

[George Hatch]

USPAP functions off the actions of the individual and the user expectations for impartiality and competency, not the nomenclature being used. If a regulator is not exercising jurisdiction over a certain assignment type then that's a function of the jurisdiction, not a function for what passes for professional appraisal practice. You can always add more than is required under the law or by user expectations. If that's how you choose to move.

 

[Terrel L. Shields]

Does not matter what THEY call it - if an appraiser offers an opinion of value it is an appraisal and should be USPAP compliant.

Employees are normally exempted from such. See BRCJR's post. He is a banker you know. I do know that Arvest banks appraisers also do evaluations and do so legally in Arkansas. But if they hire a contractor the contractors' "evaluators" are required to drop their appraisal licenses and keeping their broker licenses because they are not employees of the bank.

 

[George Hatch]

The purpose is to skirt regulations, pay less, and make more money for the user or third-party middleman.

The clients on some of these products say it takes 45 minutes, and they pay $50 -$75/. . I can not get a lawn guy to show up for $50. Even a short-form desktop takes 3 hours or more—unless one just data dumps and signs, which is what the profiteers want, so they can pad the bill three times to their customers.

About that - the minimums are so minimal that a BPO level analysis and report with some USPAP housekeeping can meet the minimums in USPAP. The FRT and GSE-type workproducts include some user-driven add-ons which aren't universally required across all appraisal practice.

That's why I always LOL a little when appraisers say they can't compete with the development and reporting in evals. What they can't do is go through all the motions of what they normally sell for the fees that go along with the reduced user-extras.

 

[BRCJR]

The purpose is to skirt regulations, pay less, and make more money for the user or third-party middleman.

The clients on some of these products say it takes 45 minutes, and they pay $50 -$75/. . I can not get a lawn guy to show up for $50. Even a short-form desktop takes 3 hours or more—unless one just data dumps and signs, which is what the profiteers want, so they can pad the bill three times to their customers.

There is "no skirting" of the regulations because Evaluations "are" governed by regulations.

It would be a great benefit to Appraisers to educated themselves on lender laws related to valuation of real property.