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"REVIEW Appraisals" are back-in favor during these Slow-Times > USPAP Violations > State Boards

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ramrcdk

Senior Member
Joined
Jan 15, 2008
Professional Status
Certified Residential Appraiser
State
North Carolina
Working RE Article 11/16/22
Sins of the Past Are Back to Haunt Appraisers
by Richard Hagar, SRA
IMPORTANT HIGHLIGHTS: Read the Article
Since 2018+-, The list of sloppy appraisal practices is almost endless, and over the past few years were accepted. Why? Because banks, borrowers, and agents were screaming that slow appraisal turn-around times "harmed" their buyers (and the agent's commission). So, sloppy work was tolerated, but now our world has changed.
One of Many Changes
Federal law states that all appraisals must be reviewed and to that point, Fannie Mae recently sent out a notice "reminding" lenders of their requirement to perform post-closing appraisal reviews. Personally, I believe they should have reviewed appraisals prior to funding

Now under Federal law, if a lender, Fannie Mae, or (any other person-article error? (EDITED) becomes aware of USPAP violations likely to have an impact on the value conclusion, then the appraiser must be reported to appropriate state licensing agencies.
Check List of Results: Check to determine that the appraiser is not on Fannie Mae's AQM list.
And a final instruction: If the reviewer identifies material errors in the appraisal report that invalidates the appraiser's opinion of market value…the lender must self-report to Fannie Mae. So, what are they going to do if Fannie Mae or the lender spots a problem? Well, they are going to turn the appraiser into the state as a way of protecting themselves if the loan goes sideways. This way lenders can shift blame forcing the appraiser to pay for the lender's losses.
............................ Well, for the most part, it's based on the quality of the appraisals delivered to lenders over the past five years. Do you believe that the quality of your work ranks you as a tier 1 appraiser or do you have a little concern about your rating? Tier 1 appraisers have little to fear but tier 2 and 3 appraisers…
 
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Are you sure 'any other person' is REQUIRED to report USPAP violations? How can any entity make it incumbent on 'any other person' to REQUIRE reporting of alleged USPAP violations? Homeowners don't even know what USPAP is...
 
Are you sure 'any other person' is REQUIRED to report USPAP violations? How can any entity make it incumbent on 'any other person' to REQUIRE reporting of alleged USPAP violations? Homeowners don't even know what USPAP is...
" I " am NOT saying...
I found the Article to be brow-lifting & forewarning.

As Carnivore wisely posted: appraisers need to be aware & more proactive than ever.
 
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Are you sure 'any other person' is REQUIRED to report USPAP violations? How can any entity make it incumbent on 'any other person' to REQUIRE reporting of alleged USPAP violations? Homeowners don't even know what USPAP is...
Ethics rule: An appraiser must not knowingly permit an employee or other person to communicate a report or assignment results that are misleading or fraudulent.
 
Ethics rule: An appraiser must not knowingly permit an employee or other person to communicate a report or assignment results that are misleading or fraudulent.
What does this have to do with requiring random people to turn appraisers in for perceived USPAP violations?
 
I am NOT saying...
I found the Article to be brow-lifting.
I didn't ask if you were 'saying' that - I asked if you were sure that random people are required to turn in appraisers for perceived USPAP violations... to my knowledge, there is no federal regulation requiring random citizens to turn appraisers in. That said, there ARE mandatory reporting requirements for lenders and AMC's...
 
Working RE Article 11/16/22
Sins of the Past Are Back to Haunt Appraisers
by Richard Hagar, SRA
IMPORTANT HIGHLIGHTS: Read the Article
Since 2018+-, The list of sloppy appraisal practices is almost endless, and over the past few years were accepted. Why? Because banks, borrowers, and agents were screaming that slow appraisal turn-around times "harmed" their buyers (and the agent's commission). So, sloppy work was tolerated, but now our world has changed.
One of Many Changes
Federal law states that all appraisals must be reviewed and to that point, Fannie Mae recently sent out a notice "reminding" lenders of their requirement to perform post-closing appraisal reviews. Personally, I believe they should have reviewed appraisals prior to funding

Now under Federal law, if a lender, Fannie Mae, or any other person (like a ??disgruntled home owner??) becomes aware of USPAP violations likely to have an impact on the value conclusion, then the appraiser must be reported to appropriate state licensing agencies.
Check List of Results: Check to determine that the appraiser is not on Fannie Mae's AQM list.
And a final instruction: If the reviewer identifies material errors in the appraisal report that invalidates the appraiser's opinion of market value…the lender must self-report to Fannie Mae. So, what are they going to do if Fannie Mae or the lender spots a problem? Well, they are going to turn the appraiser into the state as a way of protecting themselves if the loan goes sideways. This way lenders can shift blame forcing the appraiser to pay for the lender's losses.
............................ Well, for the most part, it's based on the quality of the appraisals delivered to lenders over the past five years. Do you believe that the quality of your work ranks you as a tier 1 appraiser or do you have a little concern about your rating? Tier 1 appraisers have little to fear but tier 2 and 3 appraisers…
I don't see anything in the article indicating review appraisal orders will increase -even though it is highly likely some home appraisal "values " were pushed/ poorly supported
It may be in the pipeline and over months some review orders might increase but right now I am not seeing it.

Federal law states that all rappsaisls must be "reviewed" is toothless as a "review" can be a QC only compute or clerical staff checklist. Though if homeowners start defaulting or more loans go into arrears- or nervous lenders start re evaluating loan portfolios we could see a return of "real" std 2 reviews - field reviews or desk -

Making a USPAP violation mandatory reporting from a lender or client /AMC has been in effect for years and many of such "violations" are housekeeping and cant have nothing to do with a supported value or credibility.
 
Are you sure 'any other person' is REQUIRED to report USPAP violations? How can any entity make it incumbent on 'any other person' to REQUIRE reporting of alleged USPAP violations? Homeowners don't even know what USPAP is...
No.
EDIT: within the Article it states "any persons" BUT at the beginning of the Article it leaves out "any persons" with regards to quoting Federal Law. SO I will edit the post. Thanks!
 
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I tend to agree that reviews will increase, but not primarily due to slow-down. Usually forensic type reviews pick up as distressed assets pick up - which is happening now. AND - based on the mandatory reporting requirements, I'd expect to see an increase in states receiving complaints. And I FULLY agree that appraisers were sloppy during the maelstrom, so yeah - there are probably going to be more than a few hands slapped...
 
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