Please note these are not USPAP compliant reviews as per standard 3 of USPAP.

[Metamorphic]

I agree with all of this, but I still think that the AMCs should be responsible for the quality of the reports they procure. Until they are, they will continue to pressure appraisers with lower fees, faster turn times, and dubious products. Once they are held responsible for the report, they will be encouraged to find better appraisers, pay higher fees, and allow adequate time, and stay away from nebulous products. The pressure is always for faster and cheaper. It is going to spiral out of control eventually.

AMC's have far too many finger's in the appraisal pie not to be considered a chef. Their ability to positively or negatively affect the final product is substantial. They simply must be held to at least the core ideas of USPAP, and licensing (impartiality, public trust, competency, due diligence, regulatory scrutiny, etc).

 

[PropertyEconomics]

But the BURDEN remains with the appraiser ... that is a fact no matter what any of us want ... or pray for.

 

[CANative]

But the BURDEN remains with the appraiser ...

Of course that is true. But the question is what parts of USPAP apply in any given service? The problem with this thread is that there is not enough information to determine the basis for the statement "Please note that these are not USPAP compliant reviews."

Everyone who posts in these types of threads should have a copy of USPAP open to the Ethics Rule before posting.

 

[William K]

1234567890

 

[Restrain]

e) MANDATORY REPORTING.—Any mortgage lender, mortgage

broker, mortgage banker, real estate broker, appraisal management
company, employee of an appraisal management company, or any
other person involved in a real estate transaction involving an
appraisal in connection with a consumer credit transaction secured
by the principal dwelling of a consumer who has a reasonable
basis to believe an appraiser is failing to comply with the Uniform
Standards of Professional Appraisal Practice, is violating applicable
laws, or is otherwise engaging in unethical or unprofessional conduct,
shall refer the matter to the applicable State appraiser certifying
and licensing agency.

Note the above "in a real estate transaction ". Just looking at the request, it appears that this is for an asset management company or bank, to evaluate the BPO and appraisal to estimate the probable marketing price for a REO. This does not meet the requirements cited above. They're not asking for a Standard 3 review. What they are asking for is for the appraiser to look at the BPO and the Appraisal and make a guesstimate as to which is more reasonable, and what the probable asking price should be.

Whether you want to participate in this is your decision. Just understand what they are asking for.

 

[Carnivore]

e) MANDATORY REPORTING.—Any mortgage lender, mortgage

broker, mortgage banker, real estate broker, appraisal management
company, employee of an appraisal management company, or any
other person involved in a real estate transaction involving an
appraisal in connection with a consumer credit transaction secured
by the principal dwelling of a consumer who has a reasonable
basis to believe an appraiser is failing to comply with the Uniform
Standards of Professional Appraisal Practice, is violating applicable
laws, or is otherwise engaging in unethical or unprofessional conduct,
shall refer the matter to the applicable State appraiser certifying
and licensing agency.

Note the above "in a real estate transaction ". Just looking at the request, it appears that this is for an asset management company or bank, to evaluate the BPO and appraisal to estimate the probable marketing price for a REO. This does not meet the requirements cited above. They're not asking for a Standard 3 review. What they are asking for is for the appraiser to look at the BPO and the Appraisal and make a guesstimate as to which is more reasonable, and what the probable asking price should be.

Whether you want to participate in this is your decision. Just understand what they are asking for.

Yes your correct. Its actually a hybrid review with the appraiser also providing an appraisal(direction of value, reasonableness, etc).

Do it UPSPAP or suffer when they catch you not doing it USPAP.

For something to be an appraisal does not require it to be developed and reported by an appraiser. It is just unlicensed(illegal in my state) appraisal practice(activity, thats requireing a license).

These lame as s AMC's try to manipulate the wording so as to avoid state laws. They also try to give some of you appraisers just enough of an opening so you can rationalize away your irresponsible and unethical actions.

 

[hastalavista]

So.... I've yet to see what this report is supposed to look like, what the scope of work is, etc. Seems like a lot of conjecture here on something we don't know much about?

I agree.
And, re-reading the original post, all it says is that the assignment is not a review assignment (SR3); for me, that does not automatically imply the assignment itself is non-USPAP compliant.

This sounds like an appraisal assignment to me. As Carnivore points out, if it calls for a value conclusion by an appraiser, USPAP Standard Rules applies (specifically SR1 & 2; not 3).
Whether one can complete it consistent with USPAP and (with different state legislation) consistent with one's state-regulations cannot be determined with the information provided.

 

[AnonApprsr]

But the question is what parts of USPAP apply in any given service?

Any service for which you are hired, BECAUSE you are an appraiser. The good old classroom appraiser hat. If you're wearing it, you're legally bound by USPAP. Tell them that as an appraiser you can't do this crap, but as a regular person, you'd be happy to do it. See what they say, and to be sure to paste that all over the "widget."

As Carnivore points out, if it calls for a value conclusion by an appraiser, USPAP Standard Rules applies (specifically SR1 & 2; not 3).

So you're invoking the departure rule? Wait....

Whether one can complete it consistent with USPAP and (with different state legislation) consistent with one's state-regulations cannot be determined with the information provided.

I think I can.

 

[Mr Rex]

With all the stepped up enforcement by the USPAP police lately, I bet they have already kicked in the door and put these nefarious bastids out of bizness already.

 

[Non Sequitur]

I agree.

I don't. Here's the OP:

· Review BPOs and/or Appraisals against market data

· Verify if the value is supported based on your research

· Confirm your conclusions with comments and supporting data

· Provide a final reconciliation value



Please note these are not USPAP compliant reviews as per standard 3 of USPAP.

"Review BPOs and/or appraisals", "Verify if the value is supported", "Confirm your conclusions" and "Provide a final reconciliation value", sounds pretty straight forward.

This type of assignment is the new rage and has been discussed in several threads. A licensed/certified appraiser is required. The appraiser sits at his/her desk and reviews BPOs and appraisal reports against data sources like Trulia, Zillow, SiteX, etc. The report is web based and fill in the blank and the BPOs and reports being reviewed are nationwide. The appraiser reviews, reconciles and offers opinions of value. No mystery there.