Required AIR form

[PhiloFarnsworth]

I just got back a revision request asking that I attach a separate page to my report that contains the following:
File #: _______ Property Address: _____________________________________
Effective Date of the appraisal: _________
Fannie Mae Appraiser Independence Compliance
"AMC" certifies that the attached appraisal report for the subject property, located at: _________________ was ordered by "Bank" to :"AMC", an independent third party appraisal management company. The appraisal report was completed by an independent appraisal professional with complete non-influence and in compliance with Fannie Mae’s Appraiser Independence Policy.
The process is free of influence or attempt to influence the development, reporting, result, or review of an appraisal through coercion, extortion, collusion, compensation, instruction, inducement, intimidation, bribery, or in any other manner. "AMC" makes the extraordinary assumption that all sections of Fannie Mae’s Appraiser Independence Policy, pertaining to the lender/client relationship before and after services, have been maintained.
 "AMC" certifies that appraisal reports submitted comply with ownership and affiliation requirements as outlined in Fannie Mae’s Appraiser Independence Policy.
 Fannie Mae Appraiser Independence Policy Safe Guards
o "AMC" certifies that no indication of bias, attempts to influence or intimidation pertaining to any portion of the appraisal reporting process was transmitted from the lender to the appraiser. "AMC" acts as a 3rd party, which is independent and non-bias.
o "AMC" states that the appraisal performed on the subject property noted above was managed, ordered and completed in accordance with Dodd Frank and Appraisal Independence (AIR).
Robert xxxxx
Chief Appraiser
"AMC"
xxxxxx
xxxxxx, PA 15108
412-zzz-xxxx
Certificate of Compliance "AMC"

I have removed specific names and substituted "AMC' or "Bank".

I have been required before to include what is basically in the body of the letter in my report, but worded as it pertained to me, the appraiser. This AMC is requiring that I, after filling in the blanks, include this page in its entirety, attached to my report.

What gives? This appears to be a document that should be attached by the AMC as it is a statement by the AMC on their independence, or it should be included after my appraisal is submitted. Is this proper?

 

[Joe Flacco]

I have a couple clients that use encompass. Every time I upload a report I have to check a box that creates a form called "Certificate of Non-Influence and Dodd-Frank Compliance". Looks like this.

Property Address: XXXXXXX
Borrower Name: XXXXXX
Appraisal Order Date: XXXXXX
Appraisal Type: XXXXXX

(My name) attests that the above referenced appraisal report was completed in compliance
with the appraisal independence requirements of the federal Truth in Lending Act. In
producing this appraisal, (My name) has not been influenced, nor has been subject to an
attempt to influence, the result of this review through coercion, extortion, collusion,
compensation, intimidation, or bribery. No estimate regarding the subject property's value,
proposed loan amount, or proposed loan-to-value ratio, was provided or communicated to (My name), except if a purchase agreement was provided for a purchase transaction as
required by USPAP Standards Rule 1-5(a).

Appraiser Name: XXXXXX
Appraiser License: XXXXXX
Appraiser Company: XXXXXX

 

[PhiloFarnsworth]

I have a couple clients that use encompass. Every time I upload a report I have to check a box that creates a form called "Certificate of Non-Influence and Dodd-Frank Compliance". Looks like this.

Property Address: XXXXXXX
Borrower Name: XXXXXX
Appraisal Order Date: XXXXXX
Appraisal Type: XXXXXX

(My name) attests that the above referenced appraisal report was completed in compliance
with the appraisal independence requirements of the federal Truth in Lending Act. In
producing this appraisal, (My name) has not been influenced, nor has been subject to an
attempt to influence, the result of this review through coercion, extortion, collusion,
compensation, intimidation, or bribery. No estimate regarding the subject property's value,
proposed loan amount, or proposed loan-to-value ratio, was provided or communicated to (My name), except if a purchase agreement was provided for a purchase transaction as
required by USPAP Standards Rule 1-5(a).

Appraiser Name: XXXXXX
Appraiser License: XXXXXX
Appraiser Company: XXXXXX

As have I. But you will notice that the statement you have makes a statement pertaining to you, the appraiser. The page they gave me to include says nothing about the appraiser, only about the AMC and even includes the name of an officer of the AMC. I realize that my signature is not on this page, but why would they require ME to attach it. Please be aware that the "Robert xxxxx" is NOT me. Is this proper?

 

[Joe Flacco]

I see what you are saying. I dunno. I don't think it belongs in the appraisal report. They should put it in the loan package as a separate document IMO. Even the Encompass document is separate.

The appraisal report is the appraisers product not the AMCs product.

 

[realbiz]

The page they gave me to include says nothing about the appraiser, only about the AMC and even includes the name of an officer of the AMC. I realize that my signature is not on this page, but why would they require ME to attach it. Please be aware that the "Robert xxxxx" is NOT me. Is this proper?

You know it's not proper, but if you want to continue doing AMC work they will continue to make you jump through hoops.:new_multi:
Tell them you will not do this and see what happens. Good Luck!

 

[Mike Garrett RAA]

Another fine reason....Oh, wait this isn't FHA...or is it?

 

[TxArmadillo]

It may seem strange but the page Philo posted appears to be more accurate than a few that I've seen. It talks to the lender and AMC complying with AIR requirements, not specifically the appraiser.

This required attachment probably fits nicely with a comment in the SOW that says something along of the lines of "if you receive pressure from anyone anywhere, contact us at once".

Again, I've seen worse, much worse, AIR addendums.

 

[Pat Butler]

Oh, the irony. They want you to modify your appraisal by including their form, then request that you sign that the form that indicates that they had no influence over your appraisal.

 

[TxArmadillo]

Oh, the irony. They want you to modify your appraisal by including their form, then request that you sign that the form that indicates that they had no influence over your appraisal.

It's directed toward the opinion of value, not the appraisal report forms content. The text content uses the verbiage "the result of this review".

 

[Pat Butler]

I was commenting on the basis of what was said in the OP-

The process is free of influence or attempt to influence the development, reporting, result, or review of an appraisal...