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FIRREA and USPAP

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Yes, Scott, maybe I should have made it clear that this portion of Smt-10 applies when a hypothetical condition is being used. But the original question involved the use a h.c. as the appraisal was made based on an "as completed" value.
 
Alex,

"As-Completed" appraisals include two different value scenarios and in re-rereading the question, it's not clear as to whether a hypothetical condition is used for the "as-completed" scenario as of the date of inspection (or current date), or an extraordinary assumption that the improvements are to be completed/valued as of a prospective date.

In regards to whether or not there is a USPAP violation, I think Mr. Hatch has the best advice. Fix and move on.
 
In this case, had Gatlin been more familiar with Statement 10 he probably would have provided the "As Is" for the client whether he asked for it or not.

George,
You make a good point, but there are consistency problems between what the federal guidelines require and what SMT-10 says, in part because the guidelines are written to lenders and the SMT-10 is directed to appraisers. Are any discrepancies jurisdictional exceptions to SMT-10? One of the gaps I see here, is that the guidelines tell the lenders what values they might need (at least, as-is, but maybe at other stages as well), but the guidelines don’t state they must get it all at one time, from one appraiser, in one report.

I have done the land appraisal first (not knowing it would turn into a construction loan) and then done a plans appraisal in a separate report, although I did reference the first report in the second. Are you suggesting I was required to appraise the land again, three days later, because the as-is value has to be in the same report?
 
I also usually provide an "as is" value. But in this case I was specifically asked to only provide a prospective value opinion. I am fixing the report, but this is not going to be easy. I have to value a building the has a shell, only half of the floor poured, no functioning mechanicals and a half built office.

son of a...
 
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