Joe Flacco
Elite Member
- Joined
- Jul 31, 2013
- Professional Status
- Certified Residential Appraiser
- State
- Maryland
The bottom line on the controversy is that the appraisers think the desktop+PDR combination is inferior to the conventional 1004 to the point that it poses an unacceptable risk to the lenders and the public.
Some of the lenders think that - for certain assignments - the risk is minimal and is completely acceptable.
What the combination ISN'T is a violation of the minimums in USPAP, the rules/regs at the state appraiser regulators, the appraisal policies of the GSEs or of the applicable rules and regulations which apply to the development and usage of these assignments.
That which isn't impermissible is effectively permissible.
Yeah. The lenders offloading risk to GSEs and tax payers think it is acceptable.
I am all for making it clear that there is no government guarantee and then letting the GSEs do what they want.not one without the other.