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Retrospective Appraisal Without "re"-inspection

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moretti

Junior Member
Joined
Dec 31, 2007
Professional Status
Certified Residential Appraiser
State
Oregon
Curious what everyone thoughts are.

FHA appraisal was performed at beginning of the month. Property had a deficiency that required repair. Lender has requested a new retrospective appraisal to be completed as of the same effective date as the prior appraisal for a conventional loan.

Lender is stating that no re-inspection is required and as long as I disclose that within the report. There stating that its compliant with USPAP. They are telling me that there was some sort of USPAP direction to handle it that way. They cant provide that in writing. I cant find anything that reflects this scenario.
 

Meandering

Elite Member
Joined
Feb 26, 2006
Professional Status
Real Estate Agent or Broker
State
Pennsylvania
Curious what everyone thoughts are.

FHA appraisal was performed at beginning of the month. Property had a deficiency that required repair. Lender has requested a new retrospective appraisal to be completed as of the same effective date as the prior appraisal for a conventional loan.

Lender is stating that no re-inspection is required and as long as I disclose that within the report. There stating that its compliant with USPAP. They are telling me that there was some sort of USPAP direction to handle it that way. They cant provide that in writing. I cant find anything that reflects this scenario.

They are confusing USPAP with cheap fee do-overs..

Previous intended user included FHA,
Now no FHA.

New report.

Date of value does not matter.
Scope of the Work, intended use and users matters along with,

wait for it

Changes to the property or the market conditons that are material to value.

And Ghee whiz, does fannie allow a retrospective report for lending????

Oh and state you previously performed an appraisal on the subject for same lender and FHA as an intended user.

.
 

moretti

Junior Member
Joined
Dec 31, 2007
Professional Status
Certified Residential Appraiser
State
Oregon
They are confusing USPAP with cheap fee do-overs..

Previous intended user included FHA,
Now no FHA.

New report.

Date of value does not matter.
Scope of the Work, intended use and users matters along with,

wait for it

Changes to the property or the market conditons that are material to value.

And Ghee whiz, does fannie allow a retrospective report for lending????

Oh and state you previously performed an appraisal on the subject for same lender and FHA as an intended user.

.

Well to be fair I didn't disclose how much the fee was and that's not really relevant to this question. The fee is a business decision and is treated the same way that I quote every other report that I complete.

As I mentioned the lender is requesting a new report with a retrospective date. The effective date of the appraisal would be the same date as the previous appraisal I performed. Changes to the property or changes to market conditions would not be reflective of the effective date (which again is in the past). I can see the reasoning of what they are saying in terms of being for a retrospective report.

if FNMA does not allow retrospective appraisals that would be helpful for me to show. If you have a reference to that somewhere online I would appreciate the link.

Thanks
 

timd354

Elite Member
Joined
Jan 11, 2008
Professional Status
Certified Residential Appraiser
State
Maryland
You can perform a retrospective appraisal, but not on a Fannie form.
Why is that? Unless the appraisal report is completed on the same day as the property inspection/effective date, it is in essence a retrospective appraisal. The Fannie/Freddie forms require that the effective date be the date that the appraiser's property insepction was performed, which in this case was no more than 17 days ago (per the OP the appraisal was performed the beginning of this month and it is now the 17th).

There is nothing in either USPAP or the GSE guidelines that would prevent the appraiser from completing an appraisal with an effective date approximately 2 weeks ago (whatever day he did the property inspection) and with a report date of today.
 

timd354

Elite Member
Joined
Jan 11, 2008
Professional Status
Certified Residential Appraiser
State
Maryland
if FNMA does not allow retrospective appraisals that would be helpful for me to show. If you have a reference to that somewhere online I would appreciate the link.

Thanks
No link will be forthcoming since there is nothing in the Fannie Mae Selling Guide that would not allow what the lender is requesting.
 

Randolph Kinney

Elite Member
Joined
Apr 7, 2005
Professional Status
Retired Appraiser
State
North Carolina
Why is that? Unless the appraisal report is completed on the same day as the property inspection/effective date, it is in essence a retrospective appraisal. The Fannie/Freddie forms require that the effective date be the date that the appraiser's property insepction was performed, which in this case was no more than 17 days ago (per the OP the appraisal was performed the beginning of this month and it is now the 17th).

There is nothing in either USPAP or the GSE guidelines that would prevent the appraiser from completing an appraisal with an effective date approximately 2 weeks ago (whatever day he did the property inspection) and with a report date of today.

Property had a deficiency that required repair. Lender has requested a new retrospective appraisal to be completed as of the same effective date as the prior appraisal for a conventional loan.

Sounds like a new appraisal report with a different SOW and if the condition needing repair under FHA might be also required repair under a conventional loan.

It is obvious that the lender is trying to convince the appraiser that there is nothing wrong with this approach.

As Marion pointed out, "Scope of the Work, intended use and users matters."
 

moretti

Junior Member
Joined
Dec 31, 2007
Professional Status
Certified Residential Appraiser
State
Oregon
Sounds like a new appraisal report with a different SOW and if the condition needing repair under FHA might be also required repair under a conventional loan.

It is obvious that the lender is trying to convince the appraiser that there is nothing wrong with this approach.

As Marion pointed out, "Scope of the Work, intended use and users matters."

Can you share your concerns about this approach? It is treated as a new assignment. There is a new scope of work, new work file etc and the appraisal is completed based on a previous date under the same conditions of the prior inspection.

In this case the previous repair will still be required. How they move forward with that issue is a lending decision.
 
Last edited:

Randolph Kinney

Elite Member
Joined
Apr 7, 2005
Professional Status
Retired Appraiser
State
North Carolina
What is wrong with this approach?

I believe you used the word "retrospective" as what the lender required.

The effective date of the appraisal establishes the context for the value opinion, while the date of the report indicates whether the perspective of the appraiser on the market and property as of the effective date of the appraisal was prospective, current, or retrospective.

You have to disclose a prior services in the new appraisal report. The new appraisal report is using the old appraisal report with a change in assignment conditions and scope of work, assuming no change in market conditions. You can't be misleading in your new report. Is the new appraisal report a retrospective appraisal? Or current appraisal?
 

moretti

Junior Member
Joined
Dec 31, 2007
Professional Status
Certified Residential Appraiser
State
Oregon
I believe you used the word "retrospective" as what the lender required.

The effective date of the appraisal establishes the context for the value opinion, while the date of the report indicates whether the perspective of the appraiser on the market and property as of the effective date of the appraisal was prospective, current, or retrospective.

You have to disclose a prior services in the new appraisal report. The new appraisal report is using the old appraisal report with a change in assignment conditions and scope of work, assuming no change in market conditions. You can't be misleading in your new report. Is the new appraisal report a retrospective appraisal? Or current appraisal?

Date of the report will be current with the effective date of the report being a retrospective date. Prior service would obviously be disclosed and would be expanded on to disclose that a prior service was completed on the same date as the retrospective effective date. This is what the lender is saying permits the retrospective appraisal as the information from that inspection is being utilized to complete the new report.

I can only see two possibilities here as the date of the report will be whatever date the report is completed (in the future). The effective date of the report can either be some predetermined retrospective date or at some point in the future.

I dont see how the part about a potential change in market conditions would effect a retrospective report. If it occurred after the effective date then it has to do with a different time period.
 
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