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FHA VS. Lender Guidelines

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Anthem

Thread Starter
Senior Member
Joined
Mar 10, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
Isn't there something that says the lenders guidelines cannot contradict FHA/HUD guidelines on an FHA appraisal???
 

Mr Rex

Elite Member
Joined
Jan 12, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
They cannot over rule the minimum protocol. They can require additional info that FHA does not require as part of the protocol. Of course, they better tell me up front if and how their requirements exceed FHA's or its extra work and $$$.
 

rcsone

Senior Member
Joined
May 26, 2007
Professional Status
Certified Residential Appraiser
State
Oklahoma
......lenders can request as they wish and you can or not comply as is your wish.....I generally consider additional work or addition to SOW AFTER appraisal submission worthy of their expense for my time........of course, if the results of the request is of justified inquiry, then the time should be on me.......and they are informed of same prior to my doing any more work...........tell me of our deal in the beginning, not after submission............afterall, if I cannot change my price after or during the assignment, why should they be able to add unneeded work at no cost......but my ways are not to be recommended for or to everyone.....rs
 

RSW

Elite Member
Joined
Feb 18, 2002
Professional Status
Certified Residential Appraiser
State
Tennessee
I had a lender about a month ago, change the SOW on a FHA assignment after the fact. The subject property was a new construction more than 90% complete. I did the appraisal with MPR’s and not MPS’s for the items not completed and some of them were cosmetic. After I did the CIR the lender wanted me to add an addendum stating that the subject was built to the builder’s plans and specifications. I could not do this since I did not review the plans and specifications since it was more than 90% complete. They also wanted me to take photos of the topography of the subject’s site showing positive drainage away from the foundation. Both of these requests were after the appraisal was submitted. I sent copies of the Revised appendix D showing the AS IS and Subject TO reporting requirements for new construction more than 90% complete. They just did not understand what I was saying. I told them I would review the plans but it would cost them for me to do it. I also told them that I would take photos of the topography but it would cost them for me to go back out. They finally gave in after about a week of this crap. They did not need the addendum or photos after all. It must have been a new U/W that didn’t know how to read.
 

Don Clark

Elite Member
Joined
Jan 17, 2002
Professional Status
Certified Residential Appraiser
State
Virginia
They cannot over rule the minimum protocol. They can require additional info that FHA does not require as part of the protocol. Of course, they better tell me up front if and how their requirements exceed FHA's or its extra work and $$$.

That's the way I see it.
 

Couch Potato

Elite Member
Joined
Mar 15, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
All client requested.

Isn't there something that says the lenders guidelines cannot contradict FHA/HUD guidelines on an FHA appraisal???
Under the current USPAP the client sets all the rules. What you describe is the client asking for two mutually exclusive things. You need to have the client decide, do they want an FHA appraisal or an appraisal done to some other standard? They can't request both at the same time. It is a problem identification and scope of work issue, not a competition between guidelines.
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
I had a lender about a month ago, change the SOW on a FHA assignment after the fact. The subject property was a new construction more than 90% complete. I did the appraisal with MPR’s and not MPS’s for the items not completed and some of them were cosmetic. After I did the CIR the lender wanted me to add an addendum stating that the subject was built to the builder’s plans and specifications. I could not do this since I did not review the plans and specifications since it was more than 90% complete. They also wanted me to take photos of the topography of the subject’s site showing positive drainage away from the foundation. Both of these requests were after the appraisal was submitted. I sent copies of the Revised appendix D showing the AS IS and Subject TO reporting requirements for new construction more than 90% complete. They just did not understand what I was saying. I told them I would review the plans but it would cost them for me to do it. I also told them that I would take photos of the topography but it would cost them for me to go back out. They finally gave in after about a week of this crap. They did not need the addendum or photos after all. It must have been a new U/W that didn’t know how to read.
I agree with how you handled this.
 

Marcia Langley

Senior Member
Joined
Aug 26, 2005
Professional Status
Certified Residential Appraiser
State
Missouri
Ditto Couch.

If you have an FHA number, the FHA guidelines are a minimum just like USPAP.

The client can't say "comply with FHA" and "don't comply with FHA" on the same order.

FHA is an additional user and the appraisal must meet their needs.
 

Lobo Fan

Elite Member
Joined
Nov 28, 2004
Professional Status
Certified Residential Appraiser
State
New Mexico
I think a lender can be more stringent, but not more relaxed thab FHA. For example, FHA says no comps more than 6 months old while a lender might require 90 days.
 
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