Hybrid Appraisal Extraordinary Assumptions

[BRCJR]

uhmmm,

well,

see,

kinda,

you need to know the scope of the work, before you can know if you can competently complete the appraisal. And you need to recognize and comply with the laws that pertain to the assignment, not specifically to the scope of the work.

Maybe that's why the competency rule comes before the scope of the work rule?

eh?

,

You asked what laws and I reply it depends. It does depend.
Answer my question, please.

How would the SOW differ from a higher priced vs non higher priced mortgage appraisal.

 

[Meandering]

I have placed over 10,000 appraisal assignments in my career, so far.

Not ONE time has an Appraiser inquired as to the interest rate we are charging for that particular customer.

If they did I would tell them it is confidential.

Can anyone tell me how the SOW would differ on a higher priced mortgage than one not higher priced?

But do appraisers need to know the interest rate?

Nope.

Do they need to know if the appraisal is for an assignment that requires the appraiser determine..........

wait here's a quote AND LUCKILY it's the next thing:

USPAP

SCOPE OF WORK RULE

An appraiser must properly identify the problem to be solved in order to determine the appropriate
scope of work. The appraiser must be prepared to demonstrate that the scope of work is sufficient to
produce credible assignment results.
Comment
• the extent to which the property is identified;
: Scope of work includes, but is not limited to:
• the extent to which tangible property is inspected;
• the type and extent of data researched; and
• the type and extent of analyses applied to arrive at opinions or conclusions.
Appraisers have broad flexibility and significant responsibility in determining the appropriate
scope of work for an appraisal or appraisal review assignment.
Credible assignment results require support by relevant evidence and logic. The credibility of
assignment results is always measured in the context of the intended use.

The intended use is lending, how is the appraiser supposed to know if the appraiser is by law, required to inspect the interior of the property, or if someone else can, or if a drive by is sufficient?

Oh I know,
Because IT IS THE APPRAISER, AND NOT THE CLIENT THAT DETERMINES THE SCOPE OF THE WORK.

and you know what they say............

If you've been doing it wrong all along, and no one has told you it was wrong, that still doesn't make it right.

Want to pioneer some new math with me?

Oh wait.

Maybe we're working from the lemming perspective.

Uhmm, 100,000 appraisers never read that, so they never bothered with it, so why should anyone else?


Yeah, yeah, that's the ticket right there.


Name us a sample of some of the LAWS that apply to residential lending work.

.

.

 

[TRESinc]

Uhmm, 100,000 appraisers never read that, so they never bothered with it, so why should anyone else?


Yeah, yeah, that's the ticket right there.

OR 1 appraiser who read it, interpreted it wrong (like so many other topics) and loves to preach. yeah, that's the real ticket.

 

[djd09]

IT IS THE APPRAISER, AND NOT THE CLIENT THAT DETERMINES THE SCOPE OF THE WORK.

But but but the AMC said they would send someone to inspect. Nice to have all the answers even though they may not be correct, heh?

 

[Mike Kennedy]

https://www.arb.ca.gov/cc/capandtrade/protocols/usforest/references/uspap_2008_2009.pdf

USPAP 2008-09
COMPETENCY RULE

Also visit Page U-11, Lines 315, 332, and 333 re the above

 

[Meandering]

You asked what laws and I reply it depends. It does depend.
Answer my question, please.

How would the SOW differ from a higher priced vs non higher priced mortgage appraisal.

So I have another question.

How can you know if the appraiser selected the appropriate SOW for the residential lending assignment, if you can't name the laws, that SOW had to comply with?

Is this a systemic problem for the entire mortgage industry???




Where's Timmy and Danny to answer these questions?

 

[George Hatch]

I don't know of any state regulatory programs that don't reference USPAP as the minimum standard of conduct for a licensee.

For instance, in your state the regs say

36.51. Compliance with USPAP.

A certified real estate appraiser or licensed appraiser trainee shall perform an appraisal assignment in accordance with USPAP. A certified real estate appraiser or licensed appraiser trainee who violates one or more provisions of USPAP shall be subject to disciplinary action under the act. A copy of the current edition of USPAP can be obtained by writing, telephoning or e-mailing the Appraisal Foundation at 1029 Vermont Avenue, N.W., Suite 900, Washington D.C. 20005-3517, (202) 347-7722, or info@appraisalfoundation.org, respectively.

California:

§ 3701. Standards of Professional Appraisal Practice. Every holder of a license under this part shall conform to and observe the Uniform Standards of Professional Appraisal Practice (USPAP) and any subsequent amendments thereto as promulgated by the Appraisal Standards Board of The Appraisal Foundation which standards are herein incorporated into these regulations by reference as if fully set forth herein

Texas:

Sec. 1103.405. PROFESSIONAL STANDARDS. A person who holds a certificate, license, or registration issued under this chapter shall comply with:

(1) the most current edition of the Uniform Standards of Professional Appraisal Practice adopted by the Appraisal Standards Board of the Appraisal Foundation; or

(2) other standards provided by board rule that are at least as stringent as the Uniform Standards of Professional Appraisal Practice.

Added by Acts 2005, 79th Leg., Ch. 703 (S.B. 381), Sec. 20, eff. September 1, 2005.

Amended by:

Acts 2015, 84th Leg., R.S., Ch. 950 (S.B. 1007), Sec. 45, eff. January 1, 2016.

Florida

61J1-9.001 Standards of Appraisal Practice.

All registered, licensed, or certified appraisers shall comply with the 2018-2019 Uniform Standards of Professional Appraisal Practice (USPAP), effective January 1, 2018, which is incorporated by reference. The copyrighted material may be viewed at the Division of Real Estate, 400 West Robinson Street, Hurston Building, North Tower, Suite N801, Orlando, Florida 32801. The incorporated material will be available for public inspection and examination at the Department of State, Administrative Code and Register Section, Room 701, The Capitol, Tallahassee, Florida 32399-0250.

Rulemaking Authority 475.614 FS. Law Implemented 475.613(2), 475.628 FS. History–New 8-29-06, Amended 3-24-09, 1-30-12, 4-10-14, 12-10-15, 12-31-17.

There's also Arkansas, even if the board members there are incompetent with the material as terrel has described.

Section I – General (O) Uniform Standards of Professional Appraisal Practice
The Arkansas Appraiser Licensing and Certification Board adopts the “Uniform Standards of Professional Appraisal Practice” (USPAP) as published and amended by the Appraisal Foundation for 2016-2017. This adoption shall include all parts of USPAP including the introductory sections for the purpose of judging those applicants, registrant, licensees and certificate holders with respect to the appropriateness of their conduct and activities as appraisers in the State of Arkansas.

I can go on and on. I don't know about ALL of the states but I do know that every state I've checked on so far has set it up this way.

So yeah, in conjunction with the other state rules and regs USPAP will be the performance standard against which appraisers are supposed to be judged at the state board level. And NOT federal banking laws that are enforced at the federal level.

 

[Meandering]

I like to think I have an optimistic nature.

But, my post was more serious than tongue-in-cheek (believe it or not).
If any appraiser agrees with the argument that USPAP compliance includes ensuring that every lending assignment they complete needs to have the loan components (loan amount, risk assessment, loan program, etc.) verified by the appraiser so they can ensure they competently complete the assignment, I encourage them to do so. In that case, I would think consistency and prudence demand they do it for every lending assignment because we don't want to be responsible for a client's incorrect loan categorization and lending decisions. But some might just selectively apply that standard to certain appraisal types. Every appraiser has that ability already; we are free to choose if we want to take on an assignment nor not.

But Denis,

Move your tongue, and think for a moment.

Doesn't the AMC Final Rule require that AMCs require that the appraisals that AMCs are ordering comply with USPAP?

And how can those appraisals comply with USPAP, if the appraisers can't recognize or comply with laws, that they can't even name?

And you know what?

I'm kinda wondering who is authoring those EAs in those pre-printed forms?

Wondering

Wondering

Wondering.

.

 

[BRCJR]

But do appraisers need to know the interest rate?

Nope.

Do they need to know if the appraisal is for an assignment that requires the appraiser determine..........

wait here's a quote AND LUCKILY it's the next thing:

USPAP

SCOPE OF WORK RULE

An appraiser must properly identify the problem to be solved in order to determine the appropriate
scope of work. The appraiser must be prepared to demonstrate that the scope of work is sufficient to
produce credible assignment results.
Comment
• the extent to which the property is identified;
: Scope of work includes, but is not limited to:
• the extent to which tangible property is inspected;
• the type and extent of data researched; and
• the type and extent of analyses applied to arrive at opinions or conclusions.
Appraisers have broad flexibility and significant responsibility in determining the appropriate
scope of work for an appraisal or appraisal review assignment.
Credible assignment results require support by relevant evidence and logic. The credibility of
assignment results is always measured in the context of the intended use.

The intended use is lending, how is the appraiser supposed to know if the appraiser is by law, required to inspect the interior of the property, or if someone else can, or if a drive by is sufficient?

Oh I know,
Because IT IS THE APPRAISER, AND NOT THE CLIENT THAT DETERMINES THE SCOPE OF THE WORK.

and you know what they say............

If you've been doing it wrong all along, and no one has told you it was wrong, that still doesn't make it right.

Want to pioneer some new math with me?

Oh wait.

Maybe we're working from the lemming perspective.

Uhmm, 100,000 appraisers never read that, so they never bothered with it, so why should anyone else?


Yeah, yeah, that's the ticket right there.


Name us a sample of some of the LAWS that apply to residential lending work.

.

.

You keep asking questions but do not seem willing to answer questions posed to you.

What is the SOW for a higher priced mortgage and what is the SOW for a non-higher priced mortgage?

The Competency Rule does not require you to know the specific interest rate of a mortgage. The Competency Rule does not require you to know the specific LTV ratio.
I am through beating my head against this wall you have built on this topic.
Have a good day....

 

[BRCJR]

..............................................................

So yeah, in conjunction with the other state rules and regs USPAP will be the performance standard against which appraisers are supposed to be judged at the state board level. And NOT federal banking laws that are enforced at the federal level.

Oh my, you understand it......now how did you do that???