The issue is that the AMCs are piloting these programs, nobody else, and appraisers should just
I would not know...I don't use House Canary and the loans we insure (which are mostly GSE loans) due not use House Canary's Agile Appraisals or any of their other products to value the property, so I am not really concerned about what they do at this point in time as I have too many other things that actually affect what we insure to worry about
Nope,
The issue is that you, and the AMCs, can't get around the simple truth that an interior inspection is needed, and is available, but not to the appraiser.
Plain and simply, there then is no defense for the appraiser to claim piles of EAs have not biased their opinion, by the limitation the client has placed on their inspection and research.
It's pretty easy;
Mr Appraiser how many residential lending appraisals have you performed over the years??? Thousands???
And, how many of those appraisals have you accepted client provided information that could not be verified beyond the client, yet had the potential to be a major factor impacting the market value of a property?
Oh, just a few dozen here for this client?
And why did you not attempt to get the assignment conditions extended to cover the interior inspections you have performed for all those thousands of other appraisals you have performed for other clients?
'Cause your client did not want you to inspect the home on the property, but the client wanted you to rely upon what they represented to you as the interior condition and quality of the home?
Well ghee, do we have to even question what your "peers" do?
Nobdoy swings for USPAP except appraisers. And while banking regulations might suggest some better practices, appraiser's aren't so lucky to have such a wide lattitude for what is or is not a violation.
An appraiser
must not allow assignment conditions to limit the scope of work to such a degree that the
assignment results are not credible in the context of the intended use.
Comment
• modify the assignment conditions to expand the scope of work to include gathering the
information; or
If relevant information is not available because of assignment conditions that limit
research opportunities (such as conditions that place limitations on inspection or information
gathering), an appraiser must withdraw from the assignment unless the appraiser can:
• use an extraordinary assumption about such information, if credible assignment results
can still be developed.
An appraiser must not allow the intended use of an assignment or a client’s objectives to cause the assignment results to be biased.
AO 19
Unacceptable Conditions
Certain types of conditions are unacceptable in any assignment because performing an assignment under such
conditions violates USPAP. Specifically, an assignment condition is unacceptable when it:
Unacceptable Conditions
• precludes an appraiser’s impartiality, because such a condition destroys the objectivity and
independence required for the development and communication of credible results;
• limits the scope of work to such a degree that the assignment results are not credible, given the
intended use of the assignment; or
• limits the content of a report in a way that results in the report being misleading.
Oh sorry, doesn't say you can input a pile of EAs, and then the report is suddenly not misleading, especially when the individual has a long history of performing residential lending appraisals where they were required to inspect the interior of the home and provide lots of details and commentary concerning items they are now EAing away.
Nope, can't get past appraisers holding all the liability for these "pilot programs" unless you get TAF on board to change the USPAP.