- Sep 28, 2003
- Professional Status
- Certified Residential Appraiser
- New York
I think Landsafe tried to incorporate that requirement 5-8 years ago? Or, it required the appraiser to maintain the work file for 10-years (or something like that) and required the appraiser to provide reasonable access to the files within that period.One regional lender, in their Bank/Appraiser agreement, stipulates that the bank owns the appraiser's work file for each assignment completed for said bank. Compiling an accounting statement for their storage costs, to be remitted if said bank ever invokes their ownership rights to the work file.
I That data is theirs and they can have it.
The data you collect for your analysis and opinions may include data which is subject to other confidentiality issues, that you may consider in your analysis of the market, yet not disclosue to other entities, and especially if the client has a vested interest in properties and/or businesses that are in competition with/for the subject.
Saidly, appraising commercial property really should have made this relevant in your thinking on the subject of giving away your data.
I'll look forward to your suit against the GSEs for collecting data for use in their CU and PIW programs.
Perhaps you can get the FTC to join suit..
Last time I checked, just about all the data in my reports are available via a little research (that's how I obtained it). As to the subject's specific configuration, most of that is available on public records as well.Perhaps you can wait for your previous clients to sue you.
So sad that kool aid dispensing has sunk so low as to disregard any confidential information the appraiser may have collected in their work file.
So carte blanch right over the top of AMCs, and their direct or affiliated interests. And yet sadly, USPAP still calls competency as being related to, and not violating the laws that apply to the appraiser and the assignment.
§313.10 Limits on disclosure of non-public personal information to nonaffiliated third parties.