FHA appraiser and assistant?

[lily123]

I am reviewing a FHA appraisal that is signed by a certified appraiser who indicates on appraisal and report ID form that their associate (state registered) did all the work and they supervised and take responsibility. The certified appraiser does not indicate whether they have inspected the property. I thought only the certified appraiser on the FHA roster could do the assignment. Is this an FHA violation or am I missinformed?

 

[vanguard]

What work can an appraiser trainee or licensee perform on an FHA appraisal?
The FHA Roster appraiser is required to sign the appraisal and perform all parts of the analysis and reconciliation. A trainee or licensee may assist in any part of the appraisal but the opinions and analysis must be performed by the FHA Roster appraiser, who must hold the certified residential credential at minimum. Therefore, the FHA Roster appraiser is required to select the comparables and perform all critical analyses contained in the appraisal report as well as the Market Conditions form. The FHA Roster appraiser must also inspect the subject property and at least the exterior of the comparable properties. A trainee or licensee may accompany the FHA Roster appraiser on the inspections but may not perform the inspections in place of the FHA Roster appraiser. Appraiser trainees and/or licensees may not sign the appraisal report.

 

[Lee Lansford]

I am reviewing a FHA appraisal that is signed by a certified appraiser who indicates on appraisal and report ID form that their associate (state registered) did all the work and they supervised and take responsibility. The certified appraiser does not indicate whether they have inspected the property. I thought only the certified appraiser on the FHA roster could do the assignment. Is this an FHA violation or am I missinformed?

You understand quite well.

 

[lily123]

Thank you

 

[sylphie]

Guy comes into my office the other day requesting work opportunities. He would like to work as an appraiser trainee. He has a trainee license and describes how he works currently works for another appraiser in our area, performing what he calls 'site inspections'. He discovered that he can get the necessary hours of experience with various appraisers and is looking for mire work. The appraiser he works for offices at home and therefore the trainee doesn't have the opportunity to 'work' on the actual report and tells me he isn't getting the training and experience he seeks. He is paid less than $35. to measure the property and take photos. He then sends this info electronically to the certified appraiser who completes the report. This is happening for FHA reports as well. Of course, I am unaware if the signing appraiser ever sees the property or not, but is there leeway in the certification that allows 'seeing' the interior through photos alone? Should the appraiser declare that the interior inspection is through another persons eyes and photos? Is using a trainee (no matter the skill set) as a substitute for the appraiser on site the way to keep an appraisal business profitable today?

 

[SutnNC]

Surely they must have signed and checked "did" or "did not" inspect. In either case, you are not an appraisal detective. Even if you chose to be, you'd be wasting your time. Until the ball on enforcement begins to roll, it's business as usual.

 

[sylphie]

Surely they must have signed and checked "did" or "did not" inspect. In either case, you are not an appraisal detective. Even if you chose to be, you'd be wasting your time. Until the ball on enforcement begins to roll, it's business as usual.

Thank you for your response Sut-
You are correct that I do not hold any formal credentials as an appraisal detective. Mine is a business interest, as in is there a way to make my business more profitable and remain in compliance with guidelines and regulations. Are you advising that appraisers never consider the practices of their 'peers' unless hired by some 'authority' as such? My question specifically is directed at the appraisal business model in question, using trainees in place of a personal set of eyes and then not offering any 'training' per say. Do regulations (enforcement in practice or not--)
I wasn't playing appraisal detective, this scenario walked in the office door. Are many of my peers engaging in this practice?

 

[Noreen]

Lily, to my knowledge the roster appraiser must be the inspecting appraiser to ensure to HUD that the property meets the FHA MPR. This guy is risking his roster status having a licensee do these inspections and are the exact problem with these lazy appraiser types. He'll be sorry if he gets caught. I've ben on the roster for approx 20 years and there is no way I would risk my roster status by playing his game.

 

[Mike Kennedy]

Thank you for your response Sut-
You are correct that I do not hold any formal credentials as an appraisal detective. Mine is a business interest, as in is there a way to make my business more profitable and remain in compliance with guidelines and regulations. Are you advising that appraisers never consider the practices of their 'peers' unless hired by some 'authority' as such? My question specifically is directed at the appraisal business model in question, using trainees in place of a personal set of eyes and then not offering any 'training' per say. Do regulations (enforcement in practice or not--)
I wasn't playing appraisal detective, this scenario walked in the office door. Are many of my peers engaging in this practice?

§153.21 Appraiser Trainees and Sponsors. [adopted
March 2, 1992; amended November 10, 1993; July 21,
1994; November 17, 1999; April 1, 2001; March 20,
2006; October 12, 2006; August 28, 2007; December 27,
2010 and November 1, 2011]

http://www.talcb.state.tx.us/ActAndRules/TALCB-Rules.asp

 

[TxArmadillo]

§153.21 Appraiser Trainees and Sponsors. [adopted
March 2, 1992; amended November 10, 1993; July 21,
1994; November 17, 1999; April 1, 2001; March 20,
2006; October 12, 2006; August 28, 2007; December 27,
2010 and November 1, 2011]

Sylphie, while I don't disagree with Mike's reference posted above, I'm not sure it's current.

Regardless of that, here's the Texas Occupational Law that governs appraisers and trainees in Texas. This is the law that I see quoted in virtually every publication pertaining to Texas appraising. It gives a much clearer picture of sponsors, trainees, and how trainees should/could/can be used.

Hope this helps.

[url]http://www.talcb.texas.gov/pdf/rules/TALCB-CodifiedAct.pdf[/URL]