https://theappraisercoach.com/do-third-party-inspectors-violate-USPAP
He's addressing ext "inspection" hybrids, but some relevant points. Calling observing a house from a car or street an "inspection" is a bit much but the term is commonly used. On an interior inspection, it really is an inspection, both inside and outside a property where one walks the site and looks at pools, barns etc .
I think the AMC;s, the lawyers advising and Fannie are doing a dance around USPAP for bifurcated. While USPAP does not require an inspection, in a bifurcated an inspection takes place. The question is, who does the inspection, and does inspecting the subject constitute significant appraisal assistance ( in the above FAQ, inspecting a subject is considered Tier III appraisal activities /yes.
USPAP says only an appraiser must be named if they contribute significant appraisal assistance. But to not be misleading , if an individual who is not an appraiser contributes significant appraisal assistance that should be disclosed one assumes.
The bifurcated report will have a check box and disclosure that the appraiser did not inspect, that a third party inspected ( not named with their name?)
The fact that an appraiser did not inspect is disclosed, however, did the inspection contribute significant assistance...lawyer assisted dancing around what that means, since "data collection" is not considered Tier III significant appraisal assistance. Danny is referring to the appraisal inspection as "data collection". That is deliberate to remove inspection from considered contributing significant appraisal assistance, therefore a non appraiser person can do it.
The AMC's / their attorneys prevailed in evading C and R regulatory intent by getting the regulations changed so their own data could be considered C and R ( in original C and R law in DF that was not in there).
I assume they will be successful in this too, since Fannie itself is participating and saying we have a way around USPAP and what contributes significant assistance - from now on call a subject inspection "Data collection" and as long as the inspector does not contribute judgement and opinions about the subject, that;s all it is. I read an article that the inspector will not be assigning a condition or quality rating or any other kind of judgement or opinion, If the roof is a POS caving in the inspector won't mark it C 6 or ety will check mark it older /repair issue and phot it. Will the appraiser make the decision to subject a property to inspection and repair ? Only the appraiser wilt make judgement and opinions based on the third party "data collection" (inspection), to avoid saying the inspector was involved in appraisal practice.
Amazingly clever...by having a non appraiser inspect, they avoid having to say a trainee or appraiser contributed significant appraisal assistance, and thus not name the inspector, Going forward by calling a subject inspection "data collection", they can deny the subject inspection itself is a significant appraiser TIER III activity....(even though the USPAP FAQ says it is ) The fact for lender work Fannie,FHA lender regs required a cert appraiser to inspect reversed on this basis.
“Tier III” activities). They are outlined in the FAQ referenced above as “the contribution…of substance to the development of the assignment results. In other words, the individual must contribute to the valuation analysis in a noteworthy way” (ibid). USPAP even goes on to describe the specific work that is considered to be worthy of a statement. “Examples of contributions made by appraisers that constitute significant real property appraisal assistance include the identification of comparable properties and data, inspection of the subject property and comparables, estimating accrued depreciation, or forecasting income and expenses” (ibid). Using this definition alone, one would be led to believe that a third-party inspector should be identified in the certifications. Or, should he/she?