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Interagency Guidelines, FDIC and AS IS Values

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If the particulars of a given transaction are such that the transaction is exempt from the IAEG, do the requirements/guidelines/suggestions/wishes/best practices of the IAEG apply to that transaction?

Ken, you've hit on the central question for this whole discussion. The IAEG requires as-is values, but appraisals that meet the standards of a GSE are exempt form the IAEG. As far as I know, F/F are silent on the question as-is value question. However, many lenders make the as-is value a required scope of work beliving that complying with IAEG, even if not "required", is a best practice. Where I work the intent is that all appraisals will comply the IAEG, unless there's a conflict with the GSE requirements.
 
Most lenders have requirements that exceed the minimums for FRTs or the GSEs or FHA. In doing business with a new client, if we don't ask we can't expect to know what their specifics are. It's the not-asking where many appraisers screw up.

Present company excluded, of course.

BTW, I'm now being told that the "as is" reguirement from the feds only refers to the 4 situations explicitly mentioned and not to other types of transactions; which dovetails into the stated GSE/FHA exemption.
 
If you do an appraisal for a regulated institution for a transaction that requires the services of an appraiser and employ a hypothetical condition and you fail to provide an "as is" value because you didn't know you had to you have violated the competency rule. If you did know it was required but they didn't ask and you thought it was a hassle you are probably violating the ethics rule.

Take your pick.

Since you can't document any violations in this thread, we can assume there have been none. Why you insist on whining about hypothetical violations is a mystery.
 
Just in case you didn't know, "RIF" means "reading is fundamental".

How is:



a meaningful response to:




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Either the the subject of my comment eluded your intellectual grasp or you are deliberately using a fairly dishonest and aggressive mode of debate just to score points on whatever internal scoreboard you're keeping in your head.

This is becoming a pattern with your conduct on this forum, and I'm not the only poster whose comments you have attempted to twist. I dunno if you understand it or not, but we are not engaged in campaigning for political office here where the candidate has to be perceived as omniscient in order to win the election.

Credibility in these types of discourses comes in part from acknowledging the merits of the opposition's perspective even when we disagree with some of the details. The starting point is acknowledging our common ground; what we mutually accept to be true.

Acknowledge the obvious first and then develop your reasons for disagreeing. It's the same way we work in our appraisal assignments or our review assignments. You're not losing any credibility by acknowledging that even a broken clock is right twice a day.

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In this case we should be able to agree that - regardless of when the feds issued the requirements outlined in that appendix - which by definition is used to clarify and elaborate upon the regs to which it refers and not supercede them - those requirements have already been in print for a long time. Way longer than a sizable percentage of appraisers have been appraising.

If we can agree on that much then sitting here and squabbling about when those requirements actually kicked in serves no useful purpose to the topic at hand, which is that appraisers are required to identify the readily known and knowable assignment conditions that apply to their assignments. We should both be able to agree with the idea that a published reference to which an SMT that was issued issued in 2000 referred (in the past tense, no less) and to which a current AO refers can be categorized as "knowable" even if an appraiser is inexperienced with such work and doesn't already know about these requirements. (aka incompetent)


Some of us were already in the business 25+ years ago when the feds first started instructing their regulated institutions on these requirements. You apparently don't believe us when we tell you that's how far back it goes, which is your prerogative to believe even if it does amount to you calling us liars. But that entire tangent of "when" is irrelevant to the central question of what's expected of appraisers in performing certain appraisal assignments in 2014.

So can we at least agree that in 2014 these requirements are readily knowable by any appraiser who at least asks the question "do any of the intended users need an 'as is'?" ???

If you think for one second I'm actually going to read this, you are crazier than you appear.
 
This was a (very) hot topic when I was on the ASB. In fact, part of the reason that SMT-10 was retired from USPAP was that the wording seemed to (or could be taken to) imply that an "as is" value is always required, and that wasn't accurate. The IAG provided the following in response to ASB inquiry. This was included in the 2006 edition of the FAQ book, but it came straight from the IAG with no editing by the ASB.

Per the Interagency Work Group:

The agencies' appraisal regulations require an appraisal report to include an "as is" current market value when an institution finances:

* The proposed construction or renovation of an existing property

* A property that has not met its leasing goals (non-stabilized)

* A propery with non-market lease terms (concessions that impact cash flow)

*A subdivision or tract development with unsold units

If a transaction does not include any of these types of financing situations, then an "as is" value is not required.
 
This was a (very) hot topic when I was on the ASB. In fact, part of the reason that SMT-10 was retired from USPAP was that the wording seemed to (or could be taken to) imply that an "as is" value is always required, and that wasn't accurate. The IAG provided the following in response to ASB inquiry. This was included in the 2006 edition of the FAQ book, but it came straight from the IAG with no editing by the ASB.

Per the Interagency Work Group:

It still appears to be a hot topic on this forum. Nice post.
 
Mark can tell a mobile home a mile away because mobiles have electric meters mounted on poles instead of the house.

Doofus.
 
Mark can tell a mobile home a mile away because mobiles have electric meters mounted on poles instead of the house.

Doofus.

So it's not enough for you to make a complete fool of yourself in the manufactured home thread, you need to come here and do it as well?

Have you started drinking or did you forget your medication?
 
You think you're being amusing by faking that your faking stupidity. It's not funny, it's kind of sad and pathetic. Why don't you try and make a real contribution to the forum?
 
Children children...if you are going to rough house, please go out in the back yard so as not to get any blood on the carpet....
 
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