Sounds like Provident's requirements-what you did not post was that they also say if criteria cannot be met, provide comments regarding why. Provident likes to extract a pound of flesh with a bunch of requests for info-I say they are merely trying to create the illusion that they are being diligent when in fact they likely don't have anyone that even reads the appraisal report in its entirety---some yo yo has a checklist to go by.
This is where our new policy requiring the name and phone number of the person generating the requests is going to be helpful.
As long as the client instruction includes what I highlighted, then there is no reason to decline the order.
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This is another example of clients taking on the role of teacher to appraisers. It never comes out good because clients change course with the economic times and appraisers don't (ethical ones).
The proper teaching of appraisers would be to adhere to USPAP and do the research necessary to determine the most credible comparative sales (for example, proximate, recent, and similar) and to make supported market based adjustments. This holds true whether the market values are stable, increasing, or declining.
Providing additional comments as to why/how the comps were selected and why they were considered the best available has always been necessary. This has always been true whether the client specifically asks for it or not. This is not a punishment.
During the bubble, many appraisers allowed the client to "teach" them to go a little wider, a little farther back, use a little less similar, and ignore atypical incentives in order to hit the number. These clients also taught appraisers that the USPAP-necessary additional comments were not important so appraisers routinely left that part out. They were relieved to do so because they would have had a hard time actually justifying their comp selections. The teaching was extremely effective because failure to learn these tricks ment withholding of assignments.
Now these same clients are attempting to re-train their favored appraisers to submit more credible reports. The problem is that they still are not doing it right.
In general, a requirement to arbitrarily limit comp selection, by itself, is too restrictive.
In general, adding that if those restrictions can't be met, more explanation is required, takes the sting out and allows the appraiser to do a credible appraisal. The appraiser angst that arises from this is because the client asking for further comments has always been used by them as a punishment. This is a perception problem harbored by the client-trained appraisers. Commentary is not a punishment, it is part of a credible report
in any market.
The additional coercive practices of some clients, especially AMCs, will usually come into play. The reward/punishment ranking system will continue to favor the number hitter and the faster/cheaper appraiser. These types of clients have achieved ridiculous turn times by encouraging appraisers to limit their analysis and reporting to a non-credible level. Now that they desire more credible "looking" reports, they expect the same fees, turn times, and number hitting.
My rambling is meant to point out that appraisers need to take responsibility for the credibility of their work and
stop letting clients teach them how to appraise. The teaching should come from the ethical part of the appraisal industry, not from pushy clients.
