FHA Appraisal Audit/review - Punishment

[TMG]

Last year, I was a lucky one of 150 Ca. appraisers selected for a random audit. FHA pulled three of my reports and reviewed them. They found approx. five non value changing SUBJECTIVE issues on each report.

Example: My subject had a pool/spa, and I could only find a comp with a pool and was unable to bracket the spa. I commented extensively on my search parameters and lack of a spa comp. They claimed I had not performed enough due diligence in finding a comp with a spa.

Example 2: "MLS shows sale # 1 GLA at 1,825sf, whereas pub records shows 1,750sf". Again, this was addressed/commented on, but apparently not well enough to appease the FHA gods. And more stuff like this was found, etc etc subjective minutia.

I would usually be ok with a critique, but they levied me with a 7 hour FHA course and a 15 hour USPAP course - with proctored exam. All in all I lost 3 days and $400 in course fees.

I feel my punishment was extremely harsh and bordered on harassment. They did not allow me to appeal, only gave me a deadline to turn in proof of course completion or they would escalate to the OREA. I doubted the OREA would care if I bracketed a spa, but I had no choice but to appease FHA.

I completed their punishment, but I have not accepted an FHA order since, and probably never will again. If this is how they treat their appraisers, someday they wont have any more to kick around.

 

[Terraform]

Like a slap on wrist (we are watching you). They say jump and you say how high! It's just random federal mandated bull****. No worries. That's my opinion. Don't be bullied. I suspect that you will get more work from them in the future and you will not be bothered with this again.

 

[panappr]

This is why a lot of appraisers have left the building....... completely.

 

[Terraform]

I am so sick of the scare tactics. We give an an opinion of value, do you know how difficult it is to disprove an opinion?

 

[bnmappraisal]

Ouch! That sucks to hear TMG. I have to agree with Terraform, "we give an opinion of value, do you know how difficult it is to disprove an opinion?"

I heard recently that FHA is also looking into us FHA approved are going to be under even more scrutiny and be required to do even more! I'm sure we'll be handsomely paid for our extra time (he says sarcastically!!!)

Best of luck. I hope it works out for you. Sorry you had to go through all this...

 

[Elliott]

FHA use to do lots more auditing. Typical they'd say "you shoulda used better comps." No S*** Sunshine, why don't you find them? I got use to just throwing them in the trash and not taking them serious.

No appraiser doesn't lose bad clients. Good appraisers figure out which clients are worth keeping. And thanks for the heads up....fees up for FHA.

 

[Randolph Kinney]

Just attended the HUD FHA course taught by the Santa Ana HOC.

Every FHA appraisal is being monitored, especially those appraisers that have high volume.

HUD is sending out letters or notices of deficiency (lowest level of issues) to appraisers that have made a mistake.

The next level is NOD with education; mistakes are repeated.

Next level is temporary removal from FHA panel with education.

Next level is debarment.

Bracketing is a major issue along with large unsupported adjustments.

The one thing that will get any appraiser suspended or barred from FHA is peeling paint on improvements that were constructed before 1978. They showed the front photo of a home in a appraisal with very obvious peeling paint that was never called out or conditioned subject to.

Life is tougher for the appraisers that use boilerplate and cloning. No longer will the secret list for adjustments values will be accepted.

 

[JTip]

Wait.....pool/spa.

I'm assuming an inground pool with an inground spa and not a crappy spa from the 'weekend sale' at the convention center.

Why would you not just value the spa as an extention of the pool, swim up from the pool into the spa (like the movies). Call it double dipping, line item vs square footage of the pool. That's how I would have went with it but I'm just assuming...

I quit doing FHA reports when AMCs failed to comprehend the additional exposure and compensate for it. Send it down the line to some other lucky tool.

 

[Tejus]

If you think this is bad, wait til the GSE's (Fannie Mae and Freddie Mac) blacklist Appraisers for similar issues based on their UCDP AQM analysis.

Rather than a class and fine, your appraisal career will be over.

The worst part is the GSE's have no accountability for their actions.

 

[TRESinc]

i stopped doing FHA work long ago. at one point you really had to know what you were doing and pass a decent test to get approval. then it changed to answering 10 questions, but the answers were given in an FHA class and you had to write them down verbatim or you would fail. then it change to just applying and you were on the panel. which the decrease in competency required to get FHA approved what did they think would happen?