Lender Name Change

[Have Laser-Will Travel]

If the client is asking for it, then there must be a reason. I would do it. Life is hard enough without losing your business due over something like adding another lender to the report. Revise the report, send it in, and move on to the next paying assignment. That's my advice.

One of the serious downsides to this nationwide AMC model that 'they' decided to cram down our throats is that you can't afford to really lose one as a client. I wasn't worried about losing a mtg broker as a client, I'd walk down the street and find 2 more to take their place. As I ride down the streets these days, I don't see offices with the letters "AMC" on them.

If the client is asking for it, then there must be a reason. I would do it. Life is hard enough without losing your business due over something like adding another lender to the report. Revise the report, send it in, and move on to the next paying assignment. That's my advice.

One of the serious downsides to this nationwide AMC model that 'they' decided to cram down our throats is that you can't afford to really lose one as a client. I wasn't worried about losing a mtg broker as a client, I'd walk down the street and find 2 more to take their place. As I ride down the streets these days, I don't see offices with the letters "AMC" on them.

There is a certain amount of misunderstanding on issues from the lender side which I find best to accept. Things aren't perfect.

 

[RSW]

Ok! Let me get this straight. The OP did an FHA appraisal. The Letter of engagement named two lenders and the FHA. The OP only listed 1 Lender in the appraisal report. Now, the AMC wants the appraiser to drop the first lender's name and just use the 2nd Lender's name because it will be used as a conventional loan appraisal. I am right so far?

Here is the problem. The intended use as stated in the 40001 reads like this on page 504:

The intended use of the appraisal is solely to assist FHA in assessing the risk of the Property securing the FHA-insured Mortgage (24 CFR § 200.145(b).

The intended use is wrong for a conventional loan. A new appraisal is now necessary in order to state the correct intended use as well as for the intended user now that the first Lender and the FHA are no longer involved.

 

[Have Laser-Will Travel]

Ok! Let me get this straight. The OP did an FHA appraisal. The Letter of engagement named two lenders and the FHA. The OP only listed 1 Lender in the appraisal report. Now, the AMC wants the appraiser to drop the first lender's name and just use the 2nd Lender's name because it will be used as a conventional loan appraisal. I am right so far?

Here is the problem. The intended use as stated in the 40001 reads like this on page 504:

The intended use of the appraisal is solely to assist FHA in assessing the risk of the Property securing the FHA-insured Mortgage (24 CFR § 200.145(b).

The intended use is wrong for a conventional loan. A new appraisal is now necessary in order to state the correct intended use as well as for the intended user now that the first Lender and the FHA are no longer involved.

Can't argue with that. I have to confess to a lack of due diligence in my reply (it is Saturday!)

 

[BRCJR]

Sharp RSW, sharp.

 

[OSU Beavers]

The intended users are assignment elements that are identified by the appraiser at the time of the assignment, and cannot be changed after the assignment is completed.
An appraiser may not revise an appraisal report by removing, changing, or adding intended users after an assignment has been completed.
If a party contacts an appraiser after an assignment has been completed and wants to be added to the appraisal as an intended user, the appraiser may not comply with this request. The appraiser may, however, initiate a new assignment with this additional party as the client.

 

[Mike Garrett RAA]

Not a hill I would want to die on.

 

[hastalavista]

Not a hill I would want to die on.

Nor would I if we are talking about identifying one of the named clients on a pre-printed form's client-identification section.

BTW, although this is from Appendix D, is this no longer in effect?



If it hasn't changed, then I don't see the issue.
There is nothing in the rule book I'm aware of that a lender cannot rely on an appraisal completed to FHA standards to use for the stated intended use; especially if that lender is already a named client.

Now, if it has changed, and if appraisers are required to alter the identified intended use in the appraisal report, then I stand corrected.

 

[CANative]

You are saying the same thing Can said. I agreed with him and I agree with you in that there may be no requirement to change anything.
But, why not change it if it is (a) compliant to do so; (b) easy to do so; and (c) assists the original client?

The OP asked if it could be done. The answer is yes, it can. I'd advise to do it since it isn't a big deal. On that, you and I (and Can) may disagree. You may want to charge for that; that's your prerogative as it is a business decision. As I said before, I'd opt not to charge unless uploading the report a new time was a big PIA. But that's me.

Regardless, it isn't a new assignment (IMNSHO).

I think you may not have correctly interpreted what I wrote. And when I wrote that there had been no mention of competing intended uses. That would have helped immensely and my response would have been different.

The OP and the client are trying to serve two masters in that they're trying to use one intended use for two possible scenarios. IMO, this is unacceptable.

 

[RSW]

Nor would I if we are talking about identifying one of the named clients on a pre-printed form's client-identification section.

BTW, although this is from Appendix D, is this no longer in effect?

View attachment 29567

If it hasn't changed, then I don't see the issue.
There is nothing in the rule book I'm aware of that a lender cannot rely on an appraisal completed to FHA standards to use for the stated intended use; especially if that lender is already a named client.

Now, if it has changed, and if appraisers are required to alter the identified intended use in the appraisal report, then I stand corrected.

Come on Denis, You should at least use the updated references when posting.

This is from the New Appraisal Report & Data Delivery Guide:



This is taken from the 4000.1, page 504:

 

[hastalavista]

Come on Denis, You should at least use the updated references when posting.

I thought I referenced that it was from Appendix D and asked if it was still in effect (because it is still referenced on the HUD page; that's where I captured the segment)?

I've emailed HUD to ask about this scenario. I'll share the answer with everyone when they reply (as well as the question as I asked it so everyone can judge if it addresses the specific OP issue).

But, my one question remains (which I don't know the answer to and I'll take your, RSW's, response as fact, if you happen to know):
Does FHA require that the intended use on the 1004 be modified as it is stated in the protocol you posted? Is that specific statement added to the report?
If so, then (as I said before) I stand corrected.
(notwithstanding, I'll still share the response I receive from HUD).