Hybrid

[Mr Rex]

I have made no misrepresentations of what we as appraisers can do or not do day to day. I am talking Specifically about Harry! Nice try on deflecting away from Harry!

Harry doe not need a Home Inspector or Appraisal license to measure and note condition etc as he has not performed or acted as a Home Inspection or performed or acted as an Appraiser.

 

[J Grant]

To skate the razor edge of USPAP when is a person acting as an appraiser, the non appraiser inspector will not provide any judgement or opinions or analysis of what they find at an inspection, robotic gather information and pass it on with the inspection thus proactively called "data gathering."

Might lead to some interesting conversations (or lack of them )at the inspection between homeowner or RE agent if they ask the inspector a question The inspector can't lie and say they are there as an appraiser. Many RE agents like to talk to the appraiser and provide sales etc at inspection. Wonder how that will be handled.

I'd expect a borrower/ party complaint or value dispute will have a lot more traction when the lender sent a non appraiser for the inspection portion . Whether true or not, they can accuse the inspector of negligence , and they can make the case that because the inspector is not an appraiser whatever observations they made or did not make about subject and comps affected results .. a borrower or RE agent/other can rightly accuse the lender of lacking due diligence sending a non appraiser out. Will see if it will be more of a headache for the lenders or not.

I've changed/ added comps after an inspection turns out it shows something about property ...will the inspector make 2 trips if that is needed and who will pay for it? And OMG what if that adds a day...

 

[Mr Rex]

FWIW, what other than the pre-printed Certification that say "I personally inspected" would preclude having someone else measure and "inspect" a house for an appraisal? Got USPAP?

 

[djd09]

Yeah, the United Nations will take over all appraiser regulation any day now now, LOL.

No but direct me to the part of the constitution where it says the government is allowed to take over business.

Or the part where it says they can bailout anyone.

You would fit well with the UN.

 

[DWiley]

To skate the razor edge of USPAP when is a person acting as an appraiser, the non appraiser inspector will not provide any judgement or opinions or analysis of what they find at an inspection, robotic gather information and pass it on with the inspection thus proactively called "data gathering."

Might lead to some interesting conversations (or lack of them )at the inspection between homeowner or RE agent if they ask the inspector a question The inspector can't lie and say they are there as an appraiser. Many RE agents like to talk to the appraiser and provide sales etc at inspection. Wonder how that will be handled.

I'd expect a borrower/ party complaint or value dispute will have a lot more traction when the lender sent a non appraiser for the inspection portion . Whether true or not, they can accuse the inspector of negligence , and they can make the case that because the inspector is not an appraiser whatever observations they made or did not make about subject and comps affected results .. a borrower or RE agent/other can rightly accuse the lender of lacking due diligence sending a non appraiser out. Will see if it will be more of a headache for the lenders or not.

I've changed/ added comps after an inspection turns out it shows something about property ...will the inspector make 2 trips if that is needed and who will pay for it? And OMG what if that adds a day...

Let's not kid ourselves. It will be no different than it was/is with a 2055. No one will complain about the process unless the value is less than sale price, and that will NOT be new or unique to the "hybrid" process.

 

[Carnivore]

Harry doe not need a Home Inspector or Appraisal license to measure and note condition etc as he has not performed or acted as a Home Inspection or performed or acted as an Appraiser.

there you go again trying to confuse or change what I am saying. I never said Harry was doing anything that an Appraiser does. I am saying he is receiving compensation for inspecting a house from the street or wherever and making notes(a report). As bad as a it is its still a property inspection report for compensation.

 

[Mr Rex]

there you go again trying to confuse or change what I am saying. I never said Harry was doing anything that an Appraiser does. I am saying he is receiving compensation for inspecting a house from the street or wherever and making notes(a report). As bad as a it is its still a property inspection report for compensation.

But that does not violate NC Home Inspection laws. Measuring, photos and noting overall condition do not constitute a Home Inspection. You really need to read all the rules and don't stop on the red herring "for compensation".

FWIW, he didn't doing anything a Home Inspector does either.

 

[J Grant]

I'd expect a borrower/ party complaint or value dispute will have a lot more traction when the lender sent a non appraiser for the inspection portion . Whether true or not, they can accuse the inspector of negligence , and they can make the case that because the inspector is not an appraiser whatever observations they made or did not make about subject and comps affected results .. a borrower or RE agent/other can rightly accuse the lender of lacking due diligence sending a non appraiser out. Will see if it will be more of a headache for the lenders or not.

Let's not kid ourselves. It will be no different than it was/is with a 2055. No one will complain about the process unless the value is less than sale price, and that will NOT be new or unique to the "hybrid" process.

2055 were not used for origination purposes (typically) were they? (purchases /certain refinances ) A bifurcated 1004 will and the person at house will meet inspector let them in. I've also had in past 2055 forms re assigned as full interior appraisals if a borrower was not happy with results of ext 2055.

If value or other aspect of report (sf or other ) generates a complaint would give the party complaining more traction since a non appraiser came out....but that will be a lender problem to deal with

 

[DWiley]

I've also had in past 2055 forms re assigned as full interior appraisals if a borrower was not happy with results of ext 2055.

Exactly my point

 

[George Hatch]

I think people need to step away from the label game and think in terms of the concepts involved. The actions of the individual and the expectations by the users for those actions.

What's the difference between an appraiser using a "technical home inspection" report prepared by a licensed building inspector vs using a 3rd party inspection performed by anyone other than a technical home inspector? What's the difference between using a home inspection report vs using the info and pics from an MLS listing?

Just because an individual has an appraisal license doesn't mean every type service they perform falls under the definition of appraisal practice. If you're a licensed appraiser but your activities in an appraisal assignment are limited to (for example) a clerical role such as data entry, are you engaged in "appraisal practice" and does USPAP apply to the activity of data entry? Even though the appraiser whose analyses, opinions and conclusions are contained in the appraisal report used that data entry service? Of course not. If you set the appointment - the appraiser used that service in the assignment, but does that activity fall under the definition of appraisal practice as defined? If you drove the car or held the dumb end of the tape, are those activities that fall under the definition of appraisal practice - acts that basically only an appraiser can do in such an assignment?

Appraiser and appraisal report are defined terms that DO NOT reference licensing status or any other labeling issues. This is a distinction the applies to both when the individual is acting as an appraiser as well as when they aren't. This point is made very clearly in the ETHICS RULE

An appraiser

- must not misrepresent his or her role when providing valuation services that are outside of appraisal practice (Line 195)

AO-21 speaks to the ASBs thinking on this issue directly:

A key to distinguishing an appraiser’s obligations is understanding the relationship between “valuation services” and “appraisal practice” in USPAP. Appraisal practice is a subset of valuation services.

“Valuation services” are services pertaining to aspects of property value. Appraisers and others for whom value is an issue provide valuation services. Examples include appraisal, brokerage, auctioning, property management, consulting, appraisal review and collecting market data.

“Appraisal practice” is defined as valuation services performed by an individual acting as an appraiser. Only appraisers may offer services that are considered appraisal practice. Examples include appraisal, appraisal review and collecting market data (acting as an appraiser).

Since USPAP obligations apply to those who are acting as appraisers, USPAP applies to appraisal practice.

So when there are two employees performing property inspections and one has an appraisal license but the other doesn't are they both engaged in appraising, or are they both engaged in a valuation service that doesn't involve acting as an appraiser? Because whichever it is, both the licensed and unlicensed individuals are performing the same acts for which the user expectations for both their role and their performance will be the same.