Interagency Guidelines, FDIC and AS IS Values

[CANative]

Please indicate where anything was violated in this thread. Thanks.

By not being aware of, and complying with, assignment conditions you are violating the Ethics and/or the Competency Rule.

 

[George Hatch]

The clumsy attempt is by you, George. I told you when you started this, I will accommodate you. I will get as ridiculous as you.

In other words you are unable and incapable of contradicting my observation that you mischaracterized my comments by reading into them a reference that isn't there. Even after I tried to get you back on point.

It's okay, you don't have to be embarrassed. We all make mistakes. That's an easy hole to climb out of - but your first step would be to stop digging.

 

[Mountain Man]

By not being aware of, and complying with, assignment conditions you are violating the Ethics and/or the Competency Rule.

Nope, don't agree. It is the appraiser's job to determine what the client needs... not the other way around.

 

[CANative]

Nope, don't agree. It is the appraiser's job to determine what the client needs... not the other way around.

Isn't that what I said? Or is there a typo in your post?

 

[Terrel L. Shields]

is the appraiser's job to determine what the client needs... not the other way around.

The lender is obliged to conform to the requirements of the regulating body. In a FRT, they must report an as is value. Period. The appraiser, under USPAP MUST be aware the various regulations that apply to his client....and that includes the interagency guidelines which are crystal clear

Appendix C—Deductions and Discounts

The Agencies' appraisal regulations require an appraiser to analyze and report appropriate deductions and discounts for proposed construction or renovation, partially leased buildings, non-market lease terms, and tract developments with unsold units. For such transactions, an appraisal must include the market value of the property, which should reflect the property's actual physical condition, use, and zoning designation (referred to as the "as is" value of the property), as of the effective date of the appraisal. Therefore, if the highest and best use of the property is for development to a different use, the cost of demolition and site preparation should be considered in the analysis.

 

[PropertyEconomics]

The lender is obliged to conform to the requirements of the regulating body. In a FRT, they must report an as is value. Period. The appraiser, under USPAP MUST be aware the various regulations that apply to his client....and that includes the interagency guidelines which are crystal clear

A concept apparently fought by many even though the rule has been in place since FIRREA was conceived. Its not a new concept but apparently new to many.
The authors and regulators apparently understand risk more so than many appraisers do.

 

[Terrel L. Shields]

PE - I took a class from Calvin Moye yesterday. Calvin has taught USPAP to examiners and lenders since 2001. The class is about the FRT and evaluation issues. It was attended by 50 appraisers and bankers. A show of hands indicated among the appraisers AND bankers only 4 or 5 of us had ever read the IAG... One of the first classes I took was under the old Lincoln Graduate Center and they gave us a copy of those interagency guidelines as part of class. This was pre-1994.

These are serious guidelines and everyone who does work for a bank should have one. Everyone who does work for Fannie mae should have the latest guideline from them. Everyone who does FHA needs those mortgage letters and 4150.2 manual...in fact, you agreed that you already had read it if the FHA application hasn't changed. We have more than USPAP to deal with.

 

[Ken B]

The lender is obliged to conform to the requirements of the regulating body. In a FRT, unless the transaction is subject to exemption, they must report an as is value. Period. The appraiser, under USPAP MUST be aware the various regulations that apply to his client....and that includes the interagency guidelines which are crystal clear, and which describe various exemptions to appraisal requirements and, if so exempt, additional guidance related to those exemptions..

Fixed that for you.

 

[Meandering]

A concept apparently fought by many even though the rule has been in place since FIRREA was conceived. Its not a new concept but apparently new to many.
The authors and regulators apparently understand risk more so than many appraisers do.

Funny!
:new_all_coholic:

WHO is IAEG and provide documentation as to the claims you make regarding this "group" .. please ...

http://appraisersforum.com/newreply.php?do=newreply&p=2477076

 

[Terrel L. Shields]

Fixed that for you.

In a FRT, unless the transaction is subject to exemption, they must report an as is value. Period. The appraiser, under USPAP MUST be aware the various regulations that apply to his client....and that includes the interagency guidelines which are crystal clear, and which describe various exemptions to appraisal requirements and, if so exempt, additional guidance related to those exemptions..

This exemption is intended to have limited application, especially for real estate loans secured by residential properties in which the real estate is the only form of collateral.

And I fixed that for you....direct from Appendix A..