Evaluations & USPAP - Question from a bank staff appraiser

[Mejappz]

The Foundation Announces Three Opportunities to Share Your Thoughts about Evaluations.
Concept Paper, Webinar and Public Meeting



(Washington, DC) September 3, 2019 – In early August, The Appraisal Foundation announced that the The Appraisal Standards Board would be considering adopting standards for evaluations in the Uniform Standards of Professional Appraisal Practice (USPAP). Today, we are announcing three opportunities for you to learn more, but more importantly, share your insights. The Appraisal Standards Board (ASB) is committed to hearing from every stakeholder who could be impacted by a decision from the Board.

CONCEPT PAPER

First, the Appraisal Standards Board is seeking your feedback on the concept of developing standards for performing evaluations in USPAP. To read the concept paper click here . Submit your comments to ASBcomments@appraisalfoundation.org. The comment period closes on October 11, 2019.

WEBINAR

Second, Wayne Miller, chair of the Appraisal Standards Board, and John Brenan, vice president, appraisal issues at The Appraisal Foundation will discuss the recently published Concept Paper – Evaluation Standards in USPAP, and they will also answer your questions and comments. The Webinar will be held September 10, 2019 at 1:00 pm eastern. Click here to register for the webinar. If you already have a question in mind, send your questions to aida@appraisalfoundation.org.

PUBLIC MEETING

Third, learn more and share your thoughts at the ASB public meeting on October 18, 2019. The Board will take your questions and welcomes your thoughts concerning creating standards for evaluations in USPAP. You can attend by either watching the meeting livestream or attend in person. Click here to register for the livestream or click here to register to attend in person.

They have been desperately lobbying the states, but they have been unsuccessful. If they were successful it would have meant more cha-ching for Kelley Queen and King Dave.

 

[TerryRohrer]

Investors want an appraisal so they can sue if its not worth the purchase price when they do an appraisal waiver.

Did you really think that thought through?

 

[djd09]

They have been desperately lobbying the states, but they have been unsuccessful. If they were successful it would have more cha-ching for Kelley Queen and King Dave.

what a punk brenen is...

 

[Terrel L. Shields]

If it was their intent to actively prohibit evals from being performed to appraisal specs then why do you think there is no such prohibition in the Federal Regs?

The IAG explicitly defines an evaluation and an appraisal. Yes, the IAG allows an appraiser to 'do'"" evaluations"" that comply with USPAP but doing so creates an APPRAISAL not an evaluation except where states are allowing appraisers to do the evaluation. Most states do not allow it.

I would bet 99% of "evaluations" that meet evaluation standards and not appraisal standards are done by a real estate agent, broker, or someone who simply trained as such. When my nephew as a Broker, he did a lot of evaluations that were not BPOs, but they were evaluations. They were not appraisals.

 

[George Hatch]

The point I'm making is that unless otherwise required in black and white "this is not an appraisal" isn't a requirement. That's taking a step further past saying the one isn't exactly the same as the other (which point nobody is arguing).

And you might want to look through your state's Statutes and Rules to see whether or not AR is one of the states using the same/similar verbiage as TN "this is not an appraisal" . Because not all states have such a requirement. Nor does it exist in the federal regs.

(1) This chapter does not apply to any evaluation of the value of real estate serving as collateral for a loan made by a federally regulated financial institution or to any evaluation of the value of the assets of a trust held by the institution; provided, that:
(A) The applicable federal regulator does not require an appraisal by a state-licensed or state-certified appraiser for the loan or trust;
(B) The evaluation is used solely by the financial institutions in their records to document the collateral or asset value;
(C) The evaluation shall be labeled on its face “this is not an appraisal”; and
(D) Individuals performing these evaluations may be compensated for their services.
(2) Nothing in this chapter shall prevent a state-licensed or state-certified appraiser from performing the evaluation.