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HUD Mortgagee Letter 2003-09

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Wally Jones

Senior Member
Joined
Jan 23, 2002
Professional Status
Certified Residential Appraiser
State
Florida
The letter provides the official update to appraiser qualifications for placement on the FHA roster and updates appraisal reporting requirements. (I think they even may have "unconfused" their last update on three year sales history for comps - they are now in line with USPAP. -- Or, I could be wrong --)


http://www.HUD.gov/offices/hsg/mltrmenu.cfm

(Click on 2003 Letters and go to 03-09.)
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
Also interesting in this:

The final rule provides: a) twelve-month phase-in of Appraiser
Qualifications Board (AQB) requirements for appraisers listed on
the appraiser roster, B) automatic suspension of appraisers
licensed or certified in multiple states,
c) clarification of
scope of automatic suspensions not due to State disciplinary
action.
 

Non Sequitur

Elite Member
Supporting Member
Joined
Feb 14, 2002
Professional Status
Certified Residential Appraiser
State
Louisiana
Pam I noted that to, but it isn't what it seems. Further in the letter the statement is clarified. Basically what has happened in the past is that an appraiser that was licensed in mutiple states with FHA remained on the roster even if one of the states revoked his license.

What happens now is that if you're licensed in lets say Florida & Alabama. Florida revokes, suspends, or you turn in your license to avoid action. You still are certified in Alabama. FHA can now remove you from the Alabama roster also, even if Alabama never takes any action.
 

Tim Hicks (Texas)

Elite Member
Joined
Jan 15, 2002
Professional Status
Certified Residential Appraiser
State
Texas
Darn it, I just told a group of appraisers yesterday that HUD required a three years sales history for their comps, too. Of course, they all had never heard of such a thing. Now, they get to rub this letter in my face. Now, I don't look so smart or "on top of the issues" as I did yesterday. It is hard being a Texan and trying to prove you are always right! :D
 

Brad Pack

Junior Member
Joined
Jan 15, 2002
Professional Status
General Public
State
California
Tim, don't dispair. ML 2003-07 did require a 3 year sales history for the comparable sales. It was revised to 1 year via ML 2003-09.

Wally,

FYI: USPAP does not require an appraiser to report the sales history of comparable sales, per se. The 1 year rule is a FNMA, and now HUD, supplemental requirement.

Brad Pack
 

Wally Jones

Senior Member
Joined
Jan 23, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Brad,

Of course, you're correct that USPAP doesn't state a one year sales history requirement for comparable sales. My error.

However, I think the requirement to report the "recent" sales history of comparables is strongly inferred (and seems to make good sense, if for no other reason than to head off those pesky calls from the underwriter wanting the information). AO-1 seems to give equal importance to analysis of recent and pending sales of subject and comparable properties. I choose to extend that analysis to the reporting function. Again we're reminded that many of our rules are minimum requirements and, up to a certain point, I usually lean towards providing more data (perhaps a holdover of my government days when the prevailing philosophy was "baffle 'em with b.s."). ;)

Anyhow, thanks for the correction.
 

Lawrence Suddarth

Freshman Member
Joined
Jun 26, 2003
My reading of 2003-09 left me with the impression that every time the AQB raised the bar on State Certification requirements, FHA appraisers had to get more education and experience. I was wrong. I wrote the Commissioner of the Texas Appraiser Licensing and Certification Board. He in turn, posed the question by email to the Executive Director of the Appraiser Subcommittee and the Executive Vice President of the Appraisal Foundation. If your state was in compliance with the AQB requriements at the time you received your State Certification, you are home free. If you upgrade to General Certification, then you must meet the new AQB requirements in effect at the time you apply.
 

G-man

Member
Joined
Feb 4, 2002
Professional Status
Licensed Appraiser
State
Ohio
Hee Hee, I LOVE this forum. :D I was having words with an underwriter regarding this 3 year sales history for comps :argue: . They rejected my report because it didn't have the sales history back 3 years. I said Whaaa? :blink: You don't have too. The underwriter pointed the previous 2003-07 letter and said So There! Now I can point out the new one and say So There, There :p Nothing better than rubbing a little humility into an underwriter now and then. :yellowblack:
 

Lawrence Suddarth

Freshman Member
Joined
Jun 26, 2003
Julio, This document is what the discussion is about. Thanks for posting it again. I copied the following from it: Eligibility Requirements for Placement on the FHA Appraiser Roster – Current and New Applicants

To be eligible for placement on the FHA Roster of Appraisers an appraiser must:

-3-

· Be a state-licensed or state-certified appraiser with credentials based on the minimum licensing/certification criteria issued by the Appraiser Qualifications Board (AQB) of the Appraisal Foundation. An appraiser is not deemed to have credentials based on AQB standards if the state licensing/certification requirements did not conform to AQB criteria
at the time the appraiser obtained the license or certification. This is true even if the state
· has subsequently adopted AQB criteria and has "grandfathered" previously licensed or certified appraisers (see attachment 1);
· Pass a HUD examination on FHA appraisal methods and reporting; and
· Not be listed on the GSA Suspension and Debarment List, HUD's Limited Denial of Participation List (LDP), or HUD's Credit Alert Interactive Voice Response System (CAIVRS).


Start at: "An appraiser is not deemed to." Then focus in on: "at the time." then you get the whole meaning of what HUD is trying to say. I did not understand this until I received an email from Ben Henson, the Executive Director of the Appraisal Subcommittee. The question was posed to him by Renil C. Liner, the Commissioner of the Texas Appraisal Licensing and Certification Board at my request. A copy of the question was sent to David Bunton, Executive Vice President of the Appraisal Foudation. Ben Henson answered the question and David Bunton concured. If your state was in compliance with AQB at the time you received your license/certification, you are ok. If your state was not in compliance, you have work to do. There is no raising the bar every time AQB increases the requirements. Thanks for posting this. It made for a good review.
 
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