Terrell,
Responding to your post above about complex vs. non-complex. I would agree that vacant land can be very easy. It can also be extremel;y difficult. The problem is that the difference between the two extremes involves an awful lot of information that may not be readily apparent until the appraiser is halfway through the assignment. And when things go south, they tend to do so in a hurry. A simple finished lot with all utilities stubbed to the site and SFR zoning in place is one thing. Rural land, commercial or industrial zoned lots, even multi-family lots are quite another.
In my state, the state board has held that an appraiser at the residential license or certified residential levels can appraise a site only if they could appraise what would normally go on that site. So if the site were worth $300,000, but the highest and best use for the site involved a high-dollar horse ranch, that would exceed the limitations of a residential licensee and possibly even a certified residential.
USPAP doesn't define complex assignments; FIRREA does. FIRREAs definition of complex includes a transaction where the property to be appraised, the form of ownership or market conditions are atypical. I would agree that an extreme interpretation of that would exclude all but the easiest of SFRs for a residential licensee. As it possibly should for an appraiser with limited demonstrated appraisal education and experience.
It is also true that FIRREA is aimed specifically at federally regulated lending institutions, not at appraisers. Just as USPAP's Competency Rule is applicable only to appraisers. Both sides have a responsibility to determine competence and authority to perform assignments, within their respective abilities to do so. You wouldn't recommend a ResLicensee take on a commercial appraisal for a bank just because the bank hadn't figured out they needed a GenCert, would you? That's why we need to be aware of the requirements, so that we can help our clients stay abreast.
I know you dislike form appraisal reports, particularly for vacant land. The vacant land form is one of the oldest and least USPAP-compliant report formats we have. It was never intended for any but the most simple appraisal assignments involving single residential and small commercial lots. Defnitely not intended for timber, agricultural, subdivision or other large scale land appraisals. I suppose one could write one up and add the appropriate documentation if they were desperate enough (I wouldn't). I would suggest that if a land appraisal assignment is too complex for the form, its probably too complex for the average residential appraiser.
How would you define complex?
George Hatch