FHA appraisal, change of client?

[tmcneeley]

Hey, I read those Advisory opinions. I am not confused by "Recertification of Value" and i know every assignment constitutes an appraisal, what do you think I started appraising yesterday?

You do what you want with your license. But know that every appraisal you pop out has to follow all USPAP standards, including proper reporting and not withholding any information. So If you do an update for an FHA property, with a new contract, borrower, and lender, you had better have about 3 pages in addendums explaning everything, the effect of the market decline in this instance, why your effective date is prior to the contract date, why your value might be below the contract price, etc. Then go ahead and collect your $50 for that, because I sure as hell am not doing all that for an update fee! Good luck up there in Duck country. -Go Buckeyes!

 

[Webbed Feet]

I don't think you are really reading my posts.

Hey, I read those Advisory opinions. I am not confused by "Recertification of Value" and i know every assignment constitutes an appraisal, what do you think I started appraising yesterday?

Well, it is not true that "every assignment" is a real estate appraisal. That, and now that you bring it up..............................

Seriously, It's not my fault you are posting things with gapingly incorrect or out of context informaton added. To make a point here;

You do what you want with your license. But know that every appraisal you pop out has to follow all USPAP standards, including proper reporting and not withholding any information.

Only partially true. Most all of us "withhold" (I would not say it that way) information each and every instance of us sending a "Summary" report. We are not required to include 100% of all information, as much of it is kept in our work files. That is why a "Summary" is not a "Self-Contained" report.

So If you do an update for an FHA property, with a new (sales) contract, borrower, and lender, you had better have about 3 pages in addendums explaning everything, the effect of the market decline in this instance, why your effective date is prior to the contract date,

I have to stop you at that point. I would have to take it that you are referring to a situation wherein a new sales contract was agreed to by the involved parties after the effective date of the incorporated report, but before the effective date of the second real estate appraisal and report that you are calling an "Update." Given that the new assignment (update) is taking place with an effective date after the new or altered sales contract, NO .. I do NOT have to explain why the effective date is prior to the sales contract date.. because it is not.

As far as having all sorts of addendums added to a 1004D to explain everything.... that is exactly what I've already said in my prior posts about this topic and the 1004D. The form itself does not comply with USPAP.

.......... why your value might be below the contract price, etc. Then go ahead and collect your $50 for that, because I sure as hell am not doing all that for an update fee! Good luck up there in Duck country. -Go Buckeyes!

All you have accomplished here is stated that a 1004D top half is a new assignment that must comply with everything any new assignment for a real estate appraisal must comply with. That is precisely what I've already posted. As far as your inference as to what I may have taken for fees regarding the use of a 1004D for a new assignment, your assumption only shows that you find the 1004D to be a form not worth what most client's think should be paid for the use of it, and how little you think of the form. I say good for you! I feel the same way. I have never used the 1004D top half for a new assignment, .. (an "Update" is a new assignment. We do have that one in agreement, right?)..not even once.

 

[tmcneeley]

Hey, we are in disagreement with some interpretations of the advisory opinions and USPAP. That's fine, I can live with that.


I think you are completely missing my point, stuck on your interpretations of and semantics, instead of what is really at the base of the original post, which is doing a 1004D on an FHA appraisal for a new client/new borrower. Why take on a 1004D? It has to be a new assignment anyway, why not just do a new appraisal order, and collect a full fee? If you take your car to get fixed, and they charge you for the work done, but it doesn't fix your car, then take it to another shop, you think they give you a discount? No! You missed the point, and that's okay.

And yes, every assignment where you talk about value "is" an appraisal. And you don't withhold information knowingly on a summary appraisal, you summarize everything you see.......... If you are withholding info then you are doing a summary appraisal the wrong way. Thanks for your input, but we are just going to have to disagree with what appraiser protocol should be in this case. I am in favor of taking the higher of the two fees and supporting our industry, and making the lenders pay for our services. I am not in favor of loopholes and shortcuts that benefit the banks, and decrease the value of our products. That's just one appraiser's opinon. Thanks for the good exchanges, everyone.

-Late.

 

[CANative]

And yes, every assignment where you talk about value "is" an appraisal.

Also incorrect. lol... sorry.

example: A appraisal consulting assignment.

 

[tmcneeley]

I am pretty sure that any time you talk "value" you have done an appraisal. That is like appraisal 101. Even if you are consulting you are acting as an appraisal, and subject to USPAPl. LOL!!!:new_all_coholic:

 

[Michigan CG]

Buddy, you are wrong. That is only the case when it is the same borrower/buyer. You should check up on your FHA guidelines. If it is the same buyer, then yes they can transer, but as you recall, the OP stated a new buyer/lender.

Wrong.

.........Like I stated, they can be transferred, but only when it is the same borrower,.....

Wrong.

.....don't forget that any appraisal you send out needs to be FHA compliant, and USPAP compliant........

So, the 26,000 medical office building appraisal needs to be FHA compliant?

How about the house I am appraising that was converted to a law office?

The 100 acre farm?

Your statement is incorrect.

.....Incorrect. The protocol for new buyer/borrower is simply have new borrower pay the appraisal fee to the lender and the lender refunds the old borrower. The appraisal report does not change......

Correct.

......I don't believe USPAP is changing its stance on that, but if it is please, if they are include a link or direct quote from a source....

What does USPAP have to do with FHA guidelines? The USPAP writers have nothing to do with FHA.

Sir, are you putting your FHA appraisals on a Fannie Mae/Freddie Mac form? And you think you don't have to comply with their guidelines and rules?....

OK TM......slow down. They are forms. Different lenders or clients request the use of the forms. FHA is one of those clients. Have you ever done work for a hard money lender? I do a lot of it. I violate GSE rules ALL THE TIME. The reports aren't going to a GSE.

 

[RSW]

FHA assigns a unique case number to every FHA loan. The Case Number must be entered in Loan Prospector or via LOS import for FHA loans so it will be printed on the Feedback Certificate, otherwise it won't be eligible for FHA documentation relief and credit policy revisions. Remember to enter the FHA Case Number prior to your final submission.

-Point Larusso!

-Direct from Freddie Mac. Notice is states "loan" and not property address or buyer name. It assigns them to a loan. If it is the same borrower, per HUD, FHA case numbers can be transferred, if the original bank releases them .

Here is the reference I was speaking of.

Taken from 4000.2 REV-31

4-2 TRANSFERS OF CASE NUMBERS BETWEEN LENDERS. <TOP>
A. New Lender. Lenders are expected to cooperate in the transfer of case
numbers. At the request of a borrower, the case number is to be assigned to the new lender using the Case Transfer function in FHA Connection. The transferring lender is not entitled to a fee for the transfer of a streamline refinance case number, regardless of the stage of processing the loan is in. The transferring lender may be entitled to any lock-in fee collected from the borrower at the time of application. The transferring lender is required to provide the new lender with the appraisal but is not required to provide any processing documents. If processing documents are transferred, the fee for providing these documents is to be negotiated between the lenders. No separate charge to the borrower is authorized for this transfer.

B. New Borrower Using an Existing Appraisal. If the transfer is made for a new
borrower to use an existing appraisal, the new lender is to collect an appraisal fee from the new borrower. The appraisal fee is sent to the original lender who, in turn, is to refund the fee to the original borrower.



Chapter 2
Mortgage Credit Guidelines
Page 2-17
The transferring lender must make the transfer electronically utilizing FHA
Connection. Only if extenuating circumstances exist, will HUD endorsement
technicians transfer a case number to a new lender. In those instances, an
assignment letter must be sent to the attention of an endorsement technician in the HUD Homeownership Center (HOC) to make the necessary changes in CHUMS, noting that this is an exception and stating the reason why the lender is unable to affect the transfer themselves.

If a lender will not transfer a case number, but the borrower wants to work with a new lender, the new lender should:
(1) Send the letter to the HOC specifically outlining the steps they have taken to accomplish the transfer;

(2) List what fees (if any) the original lender has requested;

(3) Provide a resolution to that request for payment for services, along with a
letter signed by the borrower stating they want to work with the new lender .

If your borrower has requested a transfer in writing, the lender must comply with their request as outlined in HUD Handbook 4000.2, 4-2A. No separate charge(s) to the borrower are authorized for the transfer of case numbers.

If the transferring lender is uncooperative, prior to contacting HUD, your Branch Manager should attempt to resolve the situation.

Please see: HUD Handbook 4000.2, 4-2 for additional information regarding
transfers of case numbers, appraisals and Master Appraisal Reports (MAR).
U.S. Department of Housing and Urban Development
451 7th Street, S.W., Washington, DC 20410


These are FHA protocol references. Where do you get the Fannie Mae and Freddie Mac stuff?