I'm Conflicted - Should I Do These Reports?

[timd354]

It doesn't really say that.

It definitely does not state that and part of what it does say about property inspections is predicated upon the specified SOW in Fannie Mae form 1004 (which the IL board's newsletter direct quotes) and that pre-printed verbiage found on the 1004 is not applicable to bifurcated appraisals.

 

[J Grant]

2. I performed a complete visual inspection of the interior and exterior areas of the subject property. I reported the condition of the improvements in factual, specific terms. I identified and reported the physical deficiencies that could affect the livability, soundness, or structural integrity of the property.

The cert page of URAR 1004- will bifurcated appraisals use a different form? Perhaps a new form developed for these types of appraisals?

 

[Meandering]

Sorry, Marion, but GSE transactions are not considered federally related transactions and any transaction under $250,000, whether or not a fedeally related transaction, does not even require an appraisal. Additionally, very few mortgages (none of which the GSE's will purchase in any case) are high risk mortgages as defined by D-F

And you found that EAs for condition are acceptable in an appraisal, or evaluation under the IAEG???

I did not post about GSEs, your reference is misplaced.

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[residentialguy]

The cert page of URAR 1004- will bifurcated appraisals use a different form? Perhaps a new form developed for these types of appraisals?

What does the URAR have to do with this? This is a different form.

 

[timd354]

2. I performed a complete visual inspection of the interior and exterior areas of the subject property. I reported the condition of the improvements in factual, specific terms. I identified and reported the physical deficiencies that could affect the livability, soundness, or structural integrity of the property.

The cert page of URAR 1004- will bifurcated appraisals use a different form? Perhaps a new form developed for these types of appraisals?

It does not take a genius that the bifurcated appraisals currently being piloted are not reported on a standard URAR/1004.

 

[residentialguy]

And you found that EAs for condition are acceptable in an appraisal, or evaluation under the IAEG???

They are not in opposition of IAEG. We don't know the risks involved in the transaction. That is not our job. Institutions should be aware that provisions in the Dodd-Frank Act address appraisal requirements for a higher-risk mortgage to a consumer. The institution should ensure that the scope of work is appropriate for the assignment.

 

[Meandering]

They are not in opposition of IAEG. We don't know the risks involved in the transaction. That is not our job. Institutions should be aware that provisions in the Dodd-Frank Act address appraisal requirements for a higher-risk mortgage to a consumer. The institution should ensure that the scope of work is appropriate for the assignment.

USPAP makes you responsible for the Scope of the Work, not the client. USPAP makes you responsible for the Scope of the Work per the Intended Use, and your scope of the work can not be so limited by the client as to make your opinions not credible for the INTENDED USE, not for the client's understanding, but for their INTENDED USE which is to lend money, that ultimately will be backed up by tax payers in some form or fashion, should the loan go belly up.

Wether the institution ensures the scope of the work is appropriate or not, it is still up to the APPRAISER to DETERMINE THE APPROPRIATE SCOPE OF THE WORK FOR THE INTENDED USE, not the institution.

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[residentialguy]

USPAP makes you responsible for the Scope of the Work, not the client. USPAP makes you responsible for the Scope of the Work per the Intended Use, and your scope of the work can not be so limited by the client as to make your opinions not credible for the INTENDED USE, not for the client's understanding, but for their INTENDED USE which is to lend money, that ultimately will be backed up by tax payers in some form or fashion, should the loan go belly up.

Wether the institution ensures the scope of the work is appropriate or not, it is still up to the APPRAISER to DETERMINE THE APPROPRIATE SCOPE OF THE WORK FOR THE INTENDED USE, not the institution.

We can only go by the institution's needs. Appraisers should turn down an assignment if we determine their request will not produce credible results...e.g. we have reason to believe that the interior is different, thus we can not stand behind an EA. That is our responsibility. However, we have no way of reviewing the risk of the borrower where they would need an interior inspection due to the high risk. The institution must determine their SOW acceptance. Again...as stated by FDIC/IAEG
Institutions should be aware that provisions in the Dodd-Frank Act address appraisal requirements for a higher-risk mortgage to a consumer. The institution should ensure that the scope of work is appropriate for the assignment.

But feel free to prove me wrong and post any of your borrowers credit information so that your appraisal SOW fulfilled their demands for their risk needs. After all, it is your responsibility.

 

[Meandering]

We can only go by the institution's needs. Appraisers should turn down an assignment if we determine their request will not produce credible results...e.g. we have reason to believe that the interior is different, thus we can not stand behind an EA. That is our responsibility. However, we have no way of reviewing the risk of the borrower where they would need an interior inspection due to the high risk. The institution must determine their SOW acceptance. Again...as stated by FDIC/IAEG
Institutions should be aware that provisions in the Dodd-Frank Act address appraisal requirements for a higher-risk mortgage to a consumer. The institution should ensure that the scope of work is appropriate for the assignment.

But feel free to prove me wrong and post any of your borrowers credit information so that your appraisal SOW fulfilled their demands for their risk needs. After all, it is your responsibility.

Okay.

You are either producing an Appraisal or an Evaluation.

If you are producing an Appraisal, you are subject to USPAP.

USPAP requires you to follow the regulations applicable to the assignment.
USPAP REQUIRES you to decline the assignment if the client/institution/lender, blah, blah limits your SOW so that your opinoins are not credible for the intended use.
The intended use is lending.
The regulations regarding lending appraisals (IAEG, FHA, USDA, VA) require the appraiser to perform an interior inspection.
The regulations regarding evaluations for lenders require an interior inspection that can not rely upon assumptions concerning condition.


You can't blame the lender/institution/client, for not telling you what you need to do produce credible results for a lending appraisal. That's why all those agencies have appraisal guidelines/regulations, not just lending guidelines/regulations.
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[residentialguy]

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

Please post this IAEG link. Thanks