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Final Inspection for different lender?

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davetheappraizer

Sophomore Member
Joined
Apr 13, 2007
Professional Status
Certified Residential Appraiser
State
Michigan
Back in December I did an inspection for a purchase of a vacant house (in good shape) and the buyers were getting an FHA loan through Lender A.

FHA requires the utilities to be functional and the attic inspected. When I was first there, the water was off (electric and gas were on,) and I wasn't able to access the attic as the panel door was sealed shut. I made the final opinion of value "Subject To" having the water turned on and the attic inspected. About 2 weeks later, I got a Final Inspection request (to use a Completion Inspection Report) from the same lender. I went back to the property and while the water was on and working, including the hot water heater, the attic was still sealed shut. I noted all of this in the CIR and sent it in.

The next day, I got an email from a different lender (Lender B.) They said that they now had the loan and wanted me to do another final inspection (using CIR again.) They included a note from Lender A stating that they authorized the Case Number be released, and that Lender B would be responsible for any further Final Inspections.

Lender B then asked me to change the name on the original report to their name, and to do a new final inspection. I told them that (a) it is against USPAP to "readdress" the report and pointed to AO-26; (b) that I have agreements with the third party company that sends me work for Lender A, as well as the third party company that sends me work for Lender B that I will NOT perform work for either company unless sent to me by their respective third party AMCs; (c) that FHA requires the attic to be inspected and it never has been, so the "Subject To"' stipulation has never been fulfilled, and (d) that I was 99.9% certain that I couldn't do a final inspection for a different client who was neither the original client nor an identified intended user.

I suggested that Lender B should either have the Lender A request a new final inspection, and if they then wanted to give my results to Lender B, that was their prerogative; OR that they should order a new appraisal in their name through their usual method (which meant that I might not get it, which is fine) if they wanted their name on the report forms.

I didn't hear back from them, so I assumed that Lender B just ordered a new appraisal report. This morning, I got an email from a different person at Lender B who claimed that they "didn't have all the pages" to my report and requested that I send them a copy.

I told them (a) my original was in PDF, so if Lender A released the loan to them, why didn't they have the PDF and (b) that they weren't the client nor an intended user to the original appraisal report and therefore I couldn't send them a copy. I also told them that it's been 70 days since the original inspection, and the attic requirement was never fulfilled and that they really ought to order a new appraisal report so it's in their name, all FHA requirements are met, and it's current.

I've never had a final inspection request from a different client than the one who ordered the original inspection. What I want to know is, (1) did I handle this correctly? and (2) Was I right to say no, or can a final inspection be performed for someone other than the original client?

Thanks in advance
 
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I also told them that it's been 700 days since the original inspection

FHA appraisals during that time frame were good for 6 months. I believe a new appraisal is going to be required.
 
You cant have two appraisals for the same case #. My biggest pet peeve is with lenders that do not know FHA rules. You dont have to change the name of the lender on the report. You are not allowed to change the lenderrs name and client B can use the appraisal with clients A name on it. Do the final and send it to the first client and have them send the appraisal to client B.



OOOPS, did not see the 700 days part. I dont think the report is valid anymore and should get another case # assigned for a new report.
 
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Oops, that was a typo.
70 days, not 700.
I fixed it.
At any rate, yes, the appraisal is "still good" for 6 months, but it is still "Subject To."
The question is whether or not I could do a final inspection for a new client based on my appraisal report for a different client.
I'm pretty sure that this falls into the same category of "retype" or an appraisal on a property that I previously performed an appraisal on for a different client.
I think that since the client changed, they need a whole new appraisal. Especially since my original was "Subject To" and the "Subject To" was never addressed.
But, I'm just trying to make sure that I handled this correctly as it was the first time this has ever come up.
 
You cant have two appraisals for the same case #. My biggest pet peeve is with lenders that do not know FHA rules. You dont have to change the name of the lender on the report. You are not allowed to change the lenderrs name and client B can use the appraisal with clients A name on it. Do the final and send it to the first client and have them send the appraisal to client B.

Yeah, I told them originally that they could use the appraisal with the original lender's name and that I can't "retype" their name.

I'm NOT going to do a Final Inspection without getting paid.
I can't just do a final and send it to the original lender and ask them to pass it on without an order.

As I noted in the OP, I told the 2nd lender that they should have the 1st lender order a Final from me and then have them send it on:
I suggested that Lender B should either have the Lender A request a new final inspection, and if they then wanted to give my results to Lender B, that was their prerogative
That never happened, and as far as I can tell never will happen.
So, lender 2 now has my original appraisal report that is "Subject To" but as far as I can tell they have no way of ordering a Final from me.
This is why I think they should just get a whole new appraisal report performed....with a new Case Number.
 
The final is for lender A and anything lender B wants is a new appraisal. I just took the update course and it clear states that a report can not be readdressed. I cant do FHA anymore, but I would assume that the case number is assigned to the client just as it is assigneed to the appraiser. The proper response is you can do a new appraisal for lender be and the appraisal maybe similar if not almost exactly the same as the original.
 
CE. it ain't what it should be!

The final is for lender A and anything lender B wants is a new appraisal. (On a test this would be a "false" answer) I just took the update course and it clear states that a report can not be readdressed. (True answer) I cant do FHA anymore, but I would assume that the case number is assigned to the client just as it is assigneed to the appraiser. (It is not always good to make assumptions, even when a person is an appraiser!) The proper response is you can do a new appraisal for lender be and the appraisal maybe similar if not almost exactly the same as the original. (What part of this is an FHA assignment did you miss?)

Oi !!! m2:
 
First, I don't see a problem with you doing a CIR for Lender B since Lender B can use the original appraisal report.

Second, a recent mortgagee letter states that an appraiser may enter into an agreement with Lender B to change the lender name. This is a new assignment. But, the appraiser is not required to do it and is a business decission. The AF has a recent Q&A on this matter about name changes on FHA appraisals.

Third, You should not have completed the appraisal report until you inspected the attic per the revised appendix D. You should have contacted the lender and scheduled another inpsection to complete the physical inspection of the subject property. I would also say the same thing goes for the water being turned off.

I have posted a copy of a letter sent to an appraiser from the FHA where he sent in appraisal report within the inspection of the attic. You should do a search or go through the FHA section of this forum and you will find many threads on this topic.
 
RSW
What mortgage letter are you refering to? I would like to read it. The last guideince that I recieved from the OCC states that a lender can NOT ask an Appraiser to readdress an appraisal. We can use an appraisal ordered by another bank, but we can not have it readdressed. If there is a conflict between regulatory agencies, I would like to have both copies on hand for the next review.
 
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