It seems to me that the most pressing (appraisal) concern at the moment is to minimize the appraiser's exposure to claims of misleading to intended users. TO ME, this means not using the 1004 format itself for these assignments.
1 - Because they visually resemble the 1004 and imply to some readers that they're the same thing; and
2 - Because dealing with the additional - and critical - disclosures in an addendum will amount to allegations that the info was buried in fine print as a means of obscuring it.
Now I can understand the point that the various *other* data systems at the lenders and the GSEs that use the XML formatting may necessitate the data fields themselves, but I think the formsware "shell" that appraisers load that data onto can be visually tweaked to have their own distinctive look, and have their own specific-to-purpose labeling, disclosures and hardwired verbiage from beginning to end.
If we know there is a large percentage of appraisers who only appraise to the form then it becomes even more critical that the formatting and structure of that form be cleaned up to better serve the legitimate interests of both the intended users AND the appraisers. If Fannie wants an 1004MC-type analysis or some new analysis in these appraisals then this is their opportunity to roll that analysis into the basic form itself and dispense with treating it as an addendum. If Fannie wants appraisers to analyze exposure time this is their opportunity to add such a section into the form itself and refrain from relying on appraisers to stick it "somewhere" in the report for reviewers to hunt for. Etc; etc.
community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.
