New USPAP Q & A October 2009

[CANative]

All it's saying is that a lender can request their own appraisal of a property the appraiser recently appraised for a different client and that an appraiser can accept such an assignment.

 

[Carnivore]

All it's saying is that a lender can request their own appraisal of a property the appraiser recently appraised for a different client and that an appraiser can accept such an assignment.

Greg,

Well USPAP does not say we can not do that. So HUD is affirming that lack of prohibition? OK, I think we all knew that.

If the original appraisal and loan package meet HUD requirements, then HUD will insure the loan. That raises a larger question;

Why does a FHA loan applicant get turned down at one lender and approved at another for the same FHA Insured loan?

 

[CANative]

Because HUD has their requirements and lenders have their own requirements. Some lenders require a 620 fico, while other can do a deal with a 590. Some don't like high ltv's when a borrower has only worked at their present job for less than six months while others don't care.

The combinations are endless.

 

[Carnivore]

Because HUD has their requirements and lenders have their own requirements. Some lenders require a 620 fico, while other can do a deal with a 590. Some don't like high ltv's when a borrower has only worked at their present job for less than six months while others don't care.

The combinations are endless.

OK, I knew you would say that, becaue I know they are doing that.

The question is why are they doing that since the loan is insured by HUD MIP?

I understand if a lender is doing a conventional loan and different PMI companies have differnet requirements. The HUD MIP is standard across the nation.

 

[CANative]

The question is why are they doing that since the loan is insured by HUD MIP?

I knew you would say that. The question is are you saying the only reason for new assignment is to try and get a more cooperative appraiser that will gravitate away from property conditions or value issues?

They're doing this because they want their own appraisal (or at least their name on someone elses appraisal).

 

[Carnivore]

I knew you would say that. The question is are you saying the only reason for new assignment is to try and get a more cooperative appraiser that will gravitate away from property conditions or value issues?

They're doing this because they want their own appraisal (or at least their name on someone elses appraisal).

I think your correct on both statements. Thats why we all should get our money up front.

 

[CANative]

The first statement was a red herring. How can they shop appraisers if they want a new appraisal from the same appraiser?

I agree with your assessment of my second statement. If they want their own appraisal they need to pay for it. And they must pay it themselves. They can't pass the fee along to the borrower.

 

[NC Appraising]

Just got off the phone with HUD. Like always, information differs person to person...


They said that the secondary market was pressuring them (take a guess) to have the appraiser to change the name to "lender B". Paper trail. My guess is that investors do not want to see lender A on the appraisal, if the mortgage was being handled is being sold by lender B.

So how do we do it?

He said it is a new assignment, with a new effective date. I know how the mortgagee letter reads... m2:http://www.HUD.gov/offices/adm/hudclips/letters/mortgagee/files/09-29ml.doc


I realize that there are two schools of thoughts on this issue.

One group says that if the lender is OK with the origianal effective date, and the scope of work is the same (lender B scope of work is the same as Lender A scope of work), the appraiser can treat it as a new assignment, and change the lenders name, new order number, and move on.


The other goup (Weebed Feet) and the guy at HUD: It is a new assignment, must have a new effective date, a new inspection date to the subject property, market analysis, search for new comparables, must be done.

He said if you do it like group one does it, and if he reviews it, you will be removed from the HUD roster list.

 

[CANative]

This is getting sillier by the minute.

 

[TJSum]

Just got off the phone with HUD. Like always, information differs person to person...


They said that the secondary market was pressuring them (take a guess) to have the appraiser to change the name to "lender B". Paper trail. Investors do not want to see lender A on the appraisal, if the loan is being sold by lender B.

So how do we do it?

He said it is a new assignment, with a new effective date. I know how the mortgagee letter reads... m2:http://www.HUD.gov/offices/adm/hudclips/letters/mortgagee/files/09-29ml.doc


I realize that there are two schools of thoughts on this issue.

One group says that if the lender is OK with the effective date, and the scope of work is the same, the appraiser can treat it as a new assignment, and change the lenders name, new order number, and move on.


The other goup (Weebed Feet) and the guy at HUD: It is a new assignment, must have a new effective date, a new inspection date to the subject property, market analysis, search for new comparables, must be done.

He said if you do it like group one does it, and if he reviews it, you will be removed from the HUD roster list.

How can it have a new effective date when the original appraisal is good for six months (four months after 1/10) ?