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How To Dispute A "notice Of Appraisal Deficiencies And Remedial Education" For FHA

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cmckelvey

Freshman Member
Joined
Mar 4, 2008
Professional Status
Certified Residential Appraiser
State
Florida
I received a notice for required education from FHA and I was hoping for some tips in disputing this. I know exactly what you are going to say. "this is why I don't do FHA." Anyway, some of the items listed were that the review appraiser measured property at 1996.5sf rounded to 1997 but not mentioning that my measurement was 1999sf and that I should have rounded my gross living area adjustments to the nearest $50 or $100. None of the items listed amount to a deficiency, such as not mentioning a toxic dump next door, etc. The comments from reviewer amount to their opinion and a bias. Additionally, the reviewer said no comments were made regarding adjustments,etc, etc, etc but I can find them in my report. Any info would be helpful. Additionally, the reviewer mentions my deficiencies in accordance with HUD Handbook 4150.2 Change 1. I am at a loss for words.
 
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Howard Klahr

Senior Member
Joined
Oct 4, 2004
Professional Status
Certified General Appraiser
State
Florida
I received a notice for required education from FHA
The notice is not likely the first communication from FHA. There is more to this than you have provided. If you wish to discuss this in an open public forum (not recommended) please provide additional details to enable those of uus to fully understand the issue.
 
D

Deleted member 134708

Guest
My old supervisor was given 1 of these, I never looked at the paperwork personally but just going off what he said out of his mouth.

There was no dispute process. It was here's your fine, classwork, do by this date of else. No rebuttal.
 

glenn walker

Elite Member
Joined
Oct 11, 2006
Professional Status
Certified Residential Appraiser
State
California
This is a little unusual not the typical letter sent from our HOC and I have read at least 30 of them in the last two years but our HOC normally only makes the appraiser take a class after they have given the appraiser a few chances to clean up their work or issues. Also is this your first letter because in our area this would have been just a letter making you aware of the issues ? No matter what at this point FHA is not going to change their minds based on any rebuttal so just suck it up and take the class. FHA is easy wait until you get a letter from Fannie Mae :) LOL
 

Tom D

Senior Member
Gold Supporting Member
Joined
May 22, 2015
Professional Status
Certified Residential Appraiser
State
Pennsylvania
take the class, you can use it for the next certification. with FHA they want a narrative report. i've seen few FHA reports come close to FHA reality. you just bite the bullet, and improve you reports like i did, after getting 2 of those letters. that was after 30 years of normal appraisals. i got a warning on a missed fireplace, but i feared telling the reviewer that they were mostly ornamental fireplaces in the row houses in this big old city. now i write 'ornamental fireplace' on the market grid. i would never dispute a HUD reviewer.
 

cmckelvey

Freshman Member
Joined
Mar 4, 2008
Professional Status
Certified Residential Appraiser
State
Florida
The notice is not likely the first communication from FHA. There is more to this than you have provided. If you wish to discuss this in an open public forum (not recommended) please provide additional details to enable those of uus to fully understand the issue.
Thanks guys, but yes this is the first correspondence I have received and I forgot to mention that the reviewer cited my deficiencies in accordance with Handbook 4150.2 Change. Yep, I know what you are going to say. Additionally, reviewer cited that they could not verify my sales. I put the official record book number as a sales source and this was reviewed from an appraisal I did in December. There are two files with the same egregious comments by reviewer and it is ridiculous. I have already called FHA and am awaiting on a callback which I may or may not receive. That reviewer needs the class more than I do.
 

cmckelvey

Freshman Member
Joined
Mar 4, 2008
Professional Status
Certified Residential Appraiser
State
Florida
take the class, you can use it for the next certification. with FHA they want a narrative report. i've seen few FHA reports come close to FHA reality. you just bite the bullet, and improve you reports like i did, after getting 2 of those letters. that was after 30 years of normal appraisals. i got a warning on a missed fireplace, but i feared telling the reviewer that they were mostly ornamental fireplaces in the row houses in this big old city. now i write 'ornamental fireplace' on the market grid. i would never dispute a HUD reviewer.
I plan on taking the classes because I don't want to be placed on a list. Like you, I thought, I can use it on my next required CE
 

cmckelvey

Freshman Member
Joined
Mar 4, 2008
Professional Status
Certified Residential Appraiser
State
Florida
Does anyone have anything to say about the fact that the reviewer mentioned my deficiencies per handbook 4150.2? The ridiculousness of this is hard to believe.
 

cmckelvey

Freshman Member
Joined
Mar 4, 2008
Professional Status
Certified Residential Appraiser
State
Florida
Seriously, I couldn't make this stuff up!
 

gregb

Elite Member
Joined
Sep 3, 2011
Professional Status
Certified General Appraiser
State
California
For what reasons may an appraiser receive a Notice of Deficiency (NOD) from FHA?
A Notice of Deficiency (NOD) refers to a formal notification from FHA to an appraiser when a review identifies gaps in due diligence and professionalism or errors or noncompliance. FHA will provide the appraiser with written notice outlining deficiencies found in a specific appraisal. An NOD is not a sanction and is not considered severe enough to require remedial education or removal. No appeal is available. An NOD is noted on the Appraiser’s record and multiple NODs may result in further action by FHA.

For additional information see Handbook 4000.1 V.E.5.e.i.(A) at https://portal.HUD.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh
 
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