FHA USPAP

[Gregory A Hicks]

I have a 1004FHA report completed for Lender A. Lender B orders a 1004D final inspection. Case number has been transferred by FHA. No permission of release from Lender A has been requested, but has not been provided.
Your thoughts?

 

[shrubberyvaluation]

I have a 1004FHA report completed for Lender A. Lender B orders a 1004D final inspection. Case number has been transferred by FHA. No permission of release from Lender A has been requested, but has not been provided.
Your thoughts?

Can't disclose confidential information is all.

 

[Tom D]

Ok, a 1004d repair, or completion of, is not an appraisal in any sense of the definition. This has been over discussed on this blog.

 

[Gregory A Hicks]

Ok, a 1004d repair, or completion of, is not an appraisal in any sense of the definition. This has been over discussed on this blog.

So releasing confidential information from the original appraisal to another lender without consent of the original lender is not a problem.

 

[Tom D]

So taking a picture of a now fixed repair item is confidential.
FHA now allows the appraisal to be transferred to another lender without having to get a new appraisal done.
The new lender now has control of the loan, and your confidential appraisal.
Oh wait, FHA says new lender can use it with the other lenders name on it. FHA is the client.

Don't do it. The lender will find someone else, and will drop you.

 

[Gregory A Hicks]

Taking a picture of the repairs no. And yes FHA can release the 'case number' to the new lender. However on the 1004D form the original lenders information "contract price, estimated value, etc..." would be confidential information. USPAP would require the release of the confidential information to the new lender would it not.

 

[Tom D]

The loan has been officially transferred to the new lender by FHA, period
The new lender has the FHA permission for their control of your appraisal, nothing is confidential. And again, FHA is your client.
So you want a new appraisal to check some repairs.
This topic has been over posted many times here.

 

[OSU Beavers]

Ok, a 1004d repair, or completion of, is not an appraisal in any sense of the definition. This has been over discussed on this blog.

The reality is some mortgage processor or the AMC will kick it back stating that you "forgot" to fill in the top half of the 1004D. "Please correct by checking the NO box confirming that the market value of the subject has not declined since the effective date of the prior appraisal."

 

[Gregory A Hicks]

The loan has been officially transferred to the new lender by FHA, period
The new lender has the FHA permission for their control of your appraisal, nothing is confidential. And again, FHA is your client.
So you want a new appraisal to check some repairs.
This topic has been over posted many times here.

The client is the original Lender, the intended users Lender and FHA. I don't want to reinvent the wheel just want to abide by USPAP. The Confidentiality Section of the Ethics Rule of USPAP and the Appraisal Institute Code of Professional Ethics provide that an appraiser must not disclose confidential information or assignment results to anyone other than the client and persons specifically authorized by the client

 

[Tom D]

I can't deal anymore with this thread.
Someone else will. The loan will close with your appraisal and a new lender, plus someone else doing the 1004d.
The next time you take a USPAP class ask the instructor. I can't cure your understanding of USPAP.
You also cannot do a new FHA appraisal, FHA not allowed to do that Your appraisal is good for 6 months, or so, whomever rhe new lender is. 1004d you put the original lender at the top and the new lender at the bottom.