Hybrid

[George Hatch]

Well that non professional practice is what you get when appraiser selection is based on the lower fee.

That unprofessional practice is what you get when an appraiser decides to behave unprofessionally because they don't think they're getting paid enough, or because they don't know how to conduct themselves appropriately. That's an appraiser deficiency, not a USPAP or user deficiency.

 

[timd354]

I think what I am trying to say is being misunderstood. I am not saying GSE guidelines conflict with USPAP. I am saying appraisals that use the GSE guidelines as the rules for selecting comparables do not comply with USPAP.

Which GSE guidelines would those be? The GSE's do not have a 1 mile guideline or anything else that would not allow appraisers to select the most relevant comps. Please cite the exact, specific GSE guideline that would cause an appraiser to select comparable sales in a non-USPAP compliant manner.

 

[Joe Flacco]

Which GSE guidelines would those be? The GSE's do not have a 1 mile guideline or anything else that would not allow appraisers to select the most relevant comps. Please cite the exact, specific GSE guideline that would cause an appraiser to select comparable sales in a non-USPAP compliant manner.

Then why do so many appraisal reports state "sales within one mile are considered". Does that statement indicate that the location attributes were properly identified or considered as required by SR 1-2(e)?

 

[Joe Flacco]

That unprofessional practice is what you get when an appraiser decides to behave unprofessionally because they don't think they're getting paid enough, or because they don't know how to conduct themselves appropriately. That's an appraiser deficiency, not a USPAP or user deficiency.

I didn't say there is a USPAP or user deficiency. I am saying AMC's and some of the chiefs are promoting the unprofessional practice by making the engagement decision based on fee. Then they just call it supply and demand.

 

[hastalavista]

I think what I am trying to say is being misunderstood. I am not saying GSE guidelines conflict with USPAP. I am saying appraisals that use the GSE guidelines as the rules for selecting comparables do not comply with USPAP.

I'll be picky and edit the above to say, "...they may not comply with the USPAP."
And, that could be the case. But if that is the case, that's an appraiser's problem because the GSE guidelines require a USPAP certification to be included in their appraisal reports and within that certification, the appraiser certifies that


Look; I think I know what you are saying. What you are saying is that there are a lot of appraisers who complete their appraisal reports putting what they believe are the GSE guidelines ahead of the USPAP and, as a consequence, they are providing non-USPAP compliant appraisals. If they are doing that and they do something that is in conflict with the USPAP, then you are correct. But that isn't a GSE-thing, that is an Appraiser-thing.

Certainly, some lenders use (or have used) the guidelines as a more strict underwriting tool than what it was intended to be by the GSEs who developed it.
A lender can require certain things in an appraisal report for it to accept the report for its lending decision. That has always been the case. If the report does not contain what the lender requires, then the lender can reject the report.
However, what has never been the case is if the lender rejects the report for a concern/omission that is not in violation of the USPAP, then the report is a bad/poor report. By definition, that cannot be. It simply means that the collateral, as analyzed by the appraiser, does not meet the lender's lending requirements. No harm/no foul on the appraiser.

FHA has a stricter guideline than the GSEs in regard to comparable selection. If, for an FHA report, there are not 3 comparable sales that closed within a year, then the property is not eligible for FHA financing.
That requirement is not a violation of the USPAP. What is a violation of the USPAP is if the appraiser put in three non-comparable sales and used them as comparable sales and concluded non-credible results.

 

[Carnivore]

deleted double entry

 

[Joe Flacco]

I'll be picky and edit the above to say, "...they may not comply with the USPAP."
And, that could be the case. But if that is the case, that's an appraiser's problem because the GSE guidelines require a USPAP certification to be included in their appraisal reports and within that certification, the appraiser certifies that
View attachment 36073

Look; I think I know what you are saying. What you are saying is that there are a lot of appraisers who complete their appraisal reports putting what they believe are the GSE guidelines ahead of the USPAP and, as a consequence, they are providing non-USPAP compliant appraisals. If they are doing that and they do something that is in conflict with the USPAP, then you are correct. But that isn't a GSE-thing, that is an Appraiser-thing.

Certainly, some lenders use (or have used) the guidelines as a more strict underwriting tool than what it was intended to be by the GSEs who developed it.
A lender can require certain things in an appraisal report for it to accept the report for its lending decision. That has always been the case. If the report does not contain what the lender requires, then the lender can reject the report.
However, what has never been the case is if the lender rejects the report for a concern/omission that is not in violation of the USPAP, then the report is a bad/poor report. By definition, that cannot be. It simply means that the collateral, as analyzed by the appraiser, does not meet the lender's lending requirements. No harm/no foul on the appraiser.

FHA has a stricter guideline than the GSEs in regard to comparable selection. If, for an FHA report, there are not 3 comparable sales that closed within a year, then the property is not eligible for FHA financing.
That requirement is not a violation of the USPAP. What is a violation of the USPAP is if the appraiser put in three non-comparable sales and used them as comparable sales and concluded non-credible results.

I don't have any issues with GSE guidelines or USPAP. My whole point is that the emphasis on speed combined with the emphasis on cost is promoting appraisals that fall short of standard 1 compliance.

 

[timd354]

Then why do so many appraisal reports state "sales within one mile are considered". Does that statement indicate that the location attributes were properly identified or considered as required by SR 1-2(e)?

There is no GSE guideline limiting comparable sales to 1 mile and there never was going back to at least 2002 (which is the oldest version of the Fannie Selling Guide available on their web site), so please try again.

Again, I am making a simple request....please cite the specific GSE guideline(s) that would cause an appraiser to select comparable sales in a non-USPAP compliant manner.

 

[chad hampton]

Your appraisal license is not an EBT card. Nor was it ever. Your business exists only to the extent you can identify a market to service and a product to sell to that market. This has always been the case in our business whether we recognized it as such or not.

If you wanted guaranteed employment you should have taken a job in gov't.

I have no idea what this means.

 

[timd354]

I don't have any issues with GSE guidelines or USPAP. My whole point is that the emphasis on speed combined with the emphasis on cost is promoting appraisals that fall short of standard 1 compliance.

While that sounds like a nice theory, you have no idea whether or not that is actually true and no data or credible evidence supporting that assertion.