Evaluations

[sputnam]

Is anyone aware of a list and summary of states that allow appraisers to do non USPAP evaluations?

 

[Terrel L. Shields]

Is anyone aware of a list and summary of states that allow appraisers to do non USPAP evaluations?

Any regulated bank in most states allow a bank employee to do evaluations to the standards of the IAG - Interagency Guidelines. Those are federal rules not state rules. No license required. Just give up your license. A few states do allow you to keep your license and do evaluations, Tennessee for one.

 

[sputnam]

Any regulated bank in most states allow a bank employee to do evaluations to the standards of the IAG - Interagency Guidelines. Those are federal rules not state rules. No license required. Just give up your license. A few states do allow you to keep your license and do evaluations, Tennessee for one.

Yeah. That's true. However, I was hoping someone had developed a state by state summary of the state laws about it. Recently, I was asked to review an eValuation that was not USPAP Compliant... even though it met the definition of 'appraisal'. The appraiser performing the eVal was not a bank employee.

 

[George Hatch]

I don't know but it seems to me that the list of states that require licensees to adhere to USPAP on Eval assignments is probably very short.

 

[JTip]

I always thought 'mandatory' states held weight (mandatory meaning ONLY licensed appraisers can provide an opinion of value for real estate for A FEE), but with BPO, evaluations, and waivers, who knows these days.

 

[J Grant]

Yeah. That's true. However, I was hoping someone had developed a state by state summary of the state laws about it. Recently, I was asked to review an eValuation that were not USPAP Compliant... even thoughit met the definition of 'appraisal'. The appraiser performing the eVal was not a bank employee.

In my opinion, if the appraiser is a licensed appraiser and signs as an appraiser, they are bound to follow USPAP when they offer an opinion of value, regardless of the label given to the report.

Evaluation is a label, a name someone gave to this product. How did they state the value - did they call it a value estimate? An opinion of value? I have never seen an evaluation, but USPAP compliance seems so simple it is puzzling why someone would not follow it. Create a work file, disclose prior sales and any prior service, a few things like that and a report is USPAP compliant - as a format anyway. USPAP addresses ethics and peer practice, which is less tangible.

 

[Dale Floyd]

Evaluations are great for appraisers who do them and are allowed by their state. Evaluations are NOT appraisals and carry no liability to the appraiser in Tennessee. Back in the days when I was young and beautiful at the bank, we called them Collateral Reviews and were only useful when a full appraisal was either overkill or unnecessary.

They've always been around in one shape or another, although not called the same things. Tennessee did a pretty good job nailing that board down when the licensing laws first came to be.

 

[Terrel L. Shields]

In my opinion, if the appraiser is a licensed appraiser and signs as an appraiser, they are bound to follow USPAP when they offer an opinion of value, regardless of the label given to the report....Evaluation is a label, a name someone gave to this product. How did they state the value

The FEDS define evaluations and state law does not apply. The question is can a licensed appraiser do an evaluation without having to comply with USPAP. Minnesota and Tennessee allow them as far as I know and are the only ones where a licensed appraiser does not have to conform to USPAP. Also, they were the original "hybrid" as the loan officer often did the inspection and took the picture and the evaluator did the rest.

 

[DWiley]

In my opinion, if the appraiser is a licensed appraiser and signs as an appraiser, they are bound to follow USPAP when they offer an opinion of value, regardless of the label given to the report.

As USPAP itself states, the obligation to follow USPAP is driven by law, regulation, agreement or choice.
In my state the law is crystal clear - an evaluation is not subject to the appraisal law and does not have to follow USPAP, even if completed by someone with an appraiser credential.

 

[Dale Floyd]

I don't believe the FEDS have ever defined a property evaluation. USPAP is a set of standards issued by the TAF, which is not the FEDS. Interagency Guidelines are a set of standards issued by the FDIC which is also not the FEDS.

I don't recall an appraiser ever being charged with anything relating to an evaluation. In Tennessee, our Attorney General even weighed in on the non-appraisal features of an evaluation by law quoting T.C.A. and USPAP as his sources of information.

But I have no issue with appraisers using USPAP to complete them.