I'm Conflicted - Should I Do These Reports?

[residentialguy]

IAEG

The appraiser's scope of work should be consistent with the extent of the research and analyses employed for similar property types, market conditions, and transactions. Therefore, an institution should be cautious in limiting the scope of the appraiser's inspection, research, or other information used to determine the property's condition and relevant market factors, which could affect the credibility of the appraisal.

Sorry,
Doesn't say it's okay to limit the appraiser's reserch and inspection based on loan amounts or credit scores of borrowers.

You should be sorry if you think that. It says that they "should be cautious in limiting". That means it is okay if they are cautious...it does not say they can't. The credibility of the appraisal goes hand in hand with the SOW and if the appraiser says that the appraisal can not be credible as ordered, they need to change the order. And drive-bys and desktops can be credible..

So...next????

 

[TRESinc]

The regulations regarding lending appraisals (IAEG, FHA, USDA, VA) require the appraiser to perform an interior inspection.

uh-oh... all those 2055/1075 reports will surely result in thousands of appraisers losing their licenses...

 

[timd354]

Here, argue with Peter, you are both lawyers.

Monday, April 16, 2012
What is the FDIC Suing Appraisers About? Some Examples of the FDIC's Specific Allegations
By Peter C

Do you even read the stuff that you reference? Peter's blog post confirms exactly what I stated. Here is a direct quote:

I have copied below the FDIC's actual allegations against several appraisers. These are word-for-word the entirety of the FDIC's claimed errors against these appraiser defendants. Please don't shoot the messenger. I'm a lawyer, not a USPAP expert, but even I know some of these things aren't really "USPAP violations" despite the FDIC's allegations.

The FDIC's favorite alleged "USPAP violations" or other alleged errors in its most recent cases have been:

• "USPAP required that [the appraiser] analyze whether the level of appreciation was sustainable;"
• The comparable is "more than one mile from the subject property;" and
• The comparable "involved a sale that was more than six months old."

Even though the complaints filed by the FDIC in court are all public documents, I've chosen to conceal the appraisers' names because I don't think the focus should be on who they are -- they could be any of tens of thousands of appraisers who delivered appraisals to failed lenders now under FDIC receivership.

Anyhow, keep on spewing your nonsense as you are gonna believe what you are gonna believe

 

[timd354]

uh-oh... all those 2055/1075 reports will surely result in thousands of appraisers losing their licenses...

LOL

 

[timd354]

The inspector, no matter how good a job they do of noting items, has no connection with the final product or value or outcome of their work .

That is actually a good thing.

The inspector will have no reason to hide or ignore unfavorable property conditions and it won't matter when the property owner/borrower tells the inspector that the amount of the mortgage loan he is refinancing is $200,000 or that he needs a property value of $250,000 in order to make the deal work.

 

[Eli]

If your telling me an appraiser can provide a more credible and reliable appraisal for PUBLIC TRUST using this format, you are crazy as a Betsy bug. You are likely crazy it will save the borrower any money.

But this is all being done for the borrower and public’s benefit?

Go suck an egg,


I hope TN disciplines the inspector for appraisal practice without a license. Just don’t call it an appraisal. Call it whatever you want.

 

[TRESinc]

.
The fact that they are not sharing the development with appraisers themselves speaks volumes. As far as the public, they are only the tax payers backing the loans, why should their input matter...

and at what exact point in the past did they ask appraisers for input on their forms or changes they wanted to make? i can't recall them asking me what i thought of the revamped 1004 when it came out...

what exactly does the general public know about creating and modifying an appraisal form? the only thing they care about on ANY form is the number.

IAEG

The appraiser's scope of work should be consistent with the extent of the research and analyses employed for similar property types, market conditions, and transactions. Therefore, an institution should be cautious in limiting the scope of the appraiser's inspection, research, or other information used to determine the property's condition and relevant market factors, which could affect the credibility of the appraisal.

Sorry,
Doesn't say it's okay to limit the appraiser's reserch and inspection based on loan amounts or credit scores of borrowers.

sorry, it doesn't say they can't either. do you read what you post??

Bifurcated appraisals introduce two layers of disconnect into the process. The inspector, no matter how good a job they do of noting items , has no connection with the final product or value or outcome of their work ( other than avoiding getting fired for being late or total screw up). The appraiser is disconnected from the property except for notes and photo.

sounds exactly like using MLS data for a basis of adjustment to comps...

 

[TRESinc]

duplicate

 

[residentialguy]

If your telling me an appraiser can provide a more credible and reliable appraisal for PUBLIC TRUST using this format, you are crazy as a Betsy bug.

No one is talking about this being "more credible". Credibility of an appraisal lies within the SOW. You could do a desktop and opine a value of $300k, than a driveby @ $325k and a Full interior @ $275k ...they are all just as credible in regards to their SOW. The SOW refers to the type and extent of the research and analyses in the assignment. Don't confuse this with accuracy of real market value. Of course, a drive-by is likely to be more accurate than a desktop, just as a 1004 is more likely to be more accurate than a drive-by. You want accuracy, order an in-depth 100 page narrative appraisal researching everything from pollution, seismic land shifts, school systems, soil determination, full market research of past, present and future projections, rents, income, and 20 comps all verified by both parties of the transaction, etc.

The lender decides what type of an appraisal is necessary for the risk of that loan and orders it. The appraiser may see that it is not sufficient for credible results with that SOW and can request an upgrade. If they won't upgrade it, the appraiser would have to decline the order, per USPAP.

 

[Eli]

The state is not going to like an inspector not being licensed to perform professional services at all. The public will want them bonded or insured too.