Is It USPAP Violation or Reviewer's Opinion

[djd09]

Reviewers for the state need to be reviewing for USPAP and not the ever-changing and ever changed whims of GSEs et al.​

That could possibly work if not for the point that USPAP requires both. When I accepted the assignment I agreed to meet the (legitimate) appraisal/reporting requirements for that assignment. Inclusive of the user-driven extras.

The only GSE whims the reviewers need to pay attention to are the one in existence as of that date.

who ever wrote the sow rule should be exiled from the appraisal profession...

 

[J Grant]

IMO- Buyer "A" loves the visual of the pond and circular drive
Buyer "B" hates the pond for its invitation to mosquitos and hates the circular drive for all the additional maintenance

Both are market indicators, where does one determine the "loss" in value from the cause?

That is why we analyze a number of sales to get a pattern and a trend and also ask RE agents to see what builders are doing, etc. It is not about individual buyers A or buyer B; it is what most buyers for this type of house indicate they will pay more for . ( a proxy for that is they typically motivated buyer in the MV definition)

Imo, separating a circular driveway for an adjustment is inane, the same for a wet bar, outdoor pergola, etc. - just minor differences among properties. The appraiser should focus on the adjustment and analysis of the important/higher $ features or defects. A pond view can be neutral, positive, or negative in market reaction. it can differ with each property and its pond. We get paid to find out which and then back it up with support.

 

[George Hatch]

Then codify the exact standards those agencies require and incorporate them into USPAP as "Supplemental Standards". So, SS 1 is FHA. SS 2 is FNMA/FREDDY. SS 3 is ....whatever. AND TOTALLY FORBID ANY DEVIATION from that standard. No lender requirements period. If FNMA does not require it, then why can Bank of Last Resort require something additional to it?

Except the intended user issue isn't limited to govt entities. It applies across all types of appraisal assignments and all types of users.

If someone only works the VA pipeline then they don't need to keep tabs on the GSE requirements. They only need to know what it takes to meet the VA requirements.
If your premise is that it's impossible for the average appraiser to become familiar with (for example) the GSE requirements PLUS any additional requirements at that particular lender then I categorically reject that idea. If some appraisers are doing it then that demonstrates that all appraisers can do it; and it also demonstrates that it isn't too much to expect .

 

[djd09]

the sow makes appraisers as common as the next lap dog...they do not want independent thinkers...ernie durbin

 

[Terrel L. Shields]

Except the intended user issue isn't limited to govt entities.

No appraiser should be sanctioned over one-off requirements. That is between appraiser and client. It should not be a review issue.

If your premise is that it's impossible for the average appraiser to become familiar with (

It is not my premise. My premise is appraisers cannot read anyone's mind. So, they need a set playing field, not post-report whimsy - which is a given with most of these bank clients. "we require this" "we require that" and, of course, it's not in the engagement letter or buried in the dross of 28 pages of requirements but you have 10 minutes to respond or lose the bid - all to be done for $290 less technology fee. And the selling guide requirements and 4000.1 sections for appraisers could easily be fitted into USPAP - that metastasizing document of ever-expanding girth. What's another dozen pages for a new Standard?

 

[George Hatch]

who ever wrote the sow rule should be exiled from the appraisal profession...

The SOWR replaced the DEPARTURE RULE and its related elements, including the Supplemental Standards Rule. The orientation is arguably reversed but the effect on what appraisers were required to do on the SR1 remain the same. Appraisers still had to meet the requirements of their assignments.

So no, that isn't the fix that would accommodate the desire many appraisers have for the fixed/immovable Universal Widget appraisal report. The autopilot approach only works when the appraiser is familiar with all of the requirements for that assignment. Ignoring the map is how the autopilot flies the plane directly into the mountain.

 

[djd09]

under the current corrupt system...the gse's could require appraiser to follow the green building standards or some other commie standard...those cannot be laws because it is unconstitutional

 

[George Hatch]

No appraiser should be sanctioned over one-off requirements. That is between appraiser and client. It should not be a review issue.

It is not my premise. My premise is appraisers cannot read anyone's mind. So, they need a set playing field, not post-report whimsy - which is a given with most of these bank clients. "we require this" "we require that" and, of course, it's not in the engagement letter or buried in the dross of 28 pages of requirements but you have 10 minutes to respond or lose the bid - all to be done for $290 less technology fee. And the selling guide requirements and 4000.1 sections for appraisers could easily be fitted into USPAP - that metastasizing document of ever-expanding girth. What's another dozen pages for a new Standard?

If the client told the appraiser they needed a prospective value and the appraiser just blew it off because it was an atypical request then that is a violation of the SOWR and SR1.2.h, Full stop. If state regulation requires compliance with USPAP (and all of them I've ever seen do require that) then the state board doesn't have the right to simply ignore that.

And you're right - nobody expects appraisers to be mindreaders. But by the same token there's no excuse for assuming one-size-fits all when we already know for a fact that isn't true.

If I asked a client if there's anything else they need and their answer is "no", or if I have accessed and used their own appraisal policy documentation then I've done my part. If I never even bothered to ask or look then proceeding on the unsupported assumption is unprofessional. And IRL that "never even bothered to look or ask" is by far the most common reason for appraisers being unaware of what their client or users actually expected for that assignment.

If we're speaking strictly in terms of what's best for the appraiser to the exclusion of every other consideration then

• "Nobody ever told me" is a defensible position for an appraiser
• "I never bothered to look or to ask" is an indefensible position for an appraiser.

 

[Terrel L. Shields]

A pond view can be neutral, positive, or negative in market reaction.

again - a "pond" (tank if you are Texan, reservoir if you are a Kansan) is a big mud puddle. In fact, a pond used by pigs or cows likely stinks in summer. And many of our subdivisions have retaining ponds - a non-event to slow the water running off and drain naturally and slowly into the watershed drainages.

 

[Terrel L. Shields]

If the client told the appraiser they needed a prospective value

That's addressed in USPAP. try again.