Review With Opinion Of Value, Out Of State Appraiser! Proteck

[J Grant]

Boards don't have an agenda to prosecute appraisers by "erecting gallows" But it is likely that if an appraiser files a complaint about a review appraisal, the appraisal that was reviewed might become part of the investigation. The OA appraisal does not have to be perfect, it should not contain material USPAP violation and have a well supported opinion of value. That's why the OP needs to separate out what kind of complaint/complaints they are making. Is it about the review appraisal itself, in which case their own appraisal might be looked at, or is it about violation of their state license laws to perform appraisals, (which might not look at either appraisal, more the fact that a review with appraisal was performed by out of state appraiser not licensed in that state (unless teh state has reciprocal license).

 

[Terrel L. Shields]

Boards don't have an agenda to prosecute appraisers by "erecting gallows

You need to get out more. This was one I'd say was way overboard. It is not unique in the annals of justice.

http://aws.state.ak.us/officeofadminhearings/Documents/REA/REA040275.pdf

http://www.touchngo.com/sp/html/sp-6673.htm

Though we review the Board's findings with great deference, we conclude that none of the Board's findings of USPAP violations were supported by
substantial evidence in light of the whole record. We thus affirm the superior court's reversal of the Board's findings of USPAP violations, and reverse the single violation that the superior court affirmed.​

 

[DWiley]

You need to get out more. This was one I'd say was way overboard. It is not unique in the annals of justice.

http://aws.state.ak.us/officeofadminhearings/Documents/REA/REA040275.pdf

http://www.touchngo.com/sp/html/sp-6673.htm

Though we review the Board's findings with great deference, we conclude that none of the Board's findings of USPAP violations were supported by
substantial evidence in light of the whole record. We thus affirm the superior court's reversal of the Board's findings of USPAP violations, and reverse the single violation that the superior court affirmed.​

I have seen both sides of this coin.

Yes, some states try to enforce their own personal views of best practice rather than enforcing USPAP. On the other hand, having been a reviewer/investigator for a state board, I have seen a LOT of legitimate cases where an appraiser or reviewer filed a complaint on the other party, and the person filing the complaint was the one with the real issue. I am not saying/implying that is the case with the OP. But I would expect that if a complaint is filed based on any appraisal review report, a hard look at the original appraisal report will almost certainly also be included as part of the case.

 

[JTip]

I got a copy of a local desktop appraisal (circa 2014) where the signing appraiser (CG) is located in Truckee, CA (hint) and the site photos were secured by a Philadelphia salesperson (4.5 hours from here).

They charged $225.

It was the most beautiful thing these eyes have ever seen.....

 

[DWiley]

I got a copy of a local desktop appraisal (circa 2014) where the signing appraiser (CG) is located in Truckee, CA (hint) and the site photos were secured by a Philadelphia salesperson (4.5 hours from here).

You note where the appraiser lives. Where was the appraiser licensed?

As addressed in another thread, "desktop" appraisals with an inspection by someone other than the appraiser have been around for a long time, and their use is spreading rapidly. Given what is happening with service times in many areas, I will be shocked if we don't see GSE adoption of such products for certain loan types in the near future. Just look at the most recent announcements about PIWs and you can see the writing on the wall. Those who are charging big fees and delivering reports back in 4 to 6 weeks right now better may hay while the sun is out, because change is coming.

 

[Meandering]

I got a copy of a local desktop appraisal (circa 2014) where the signing appraiser (CG) is located in Truckee, CA (hint) and the site photos were secured by a Philadelphia salesperson (4.5 hours from here).

They charged $225.

It was the most beautiful thing these eyes have ever seen.....

PA requires an appraiser valuing PA property to have a PA state issued license, and the report to be signed with the credentials of the appraiser. So hopefully that Standard 3 review was performed under at least a temporary state license, and was signed in accordance with the state law requirements, else, it is a USPAP violation of competency.

Zing.

.

.

 

[Terrel L. Shields]

the person filing the complaint was the one with the real issue.

It got so bad in Arkansas, our newsletter included a word from the director stating that if you file a complaint based upon your review please make sure your review is compliant.

I'm no fan of technical review (just reappraise it. At some point you have to decide on the credibility) and one reason is that too many reviewers go in with the notion the report is flawed and they nitpick...often they are newbies to boot. Further, and far more important, is the bias a reviewer carries as the baggage of being an opinion giver. That bias is subtle and often the appraiser fails to realize their own biases. Namely, they want to impose their own personal twists and turns in valuation. This goes beyond comp choices and to the heart of the way they choose comparables or define neighborhoods, the way they vet them, and the way that they make adjustments. Too many reviewers will disagree with the methods used, even when such methods are perfectly legit and otherwise not dealt with in USPAP. If it isn't a violation of USPAP AND, if secondary market, doesn't violate the guidelines explicitly, then the fact they arrived at $40/SF adjustment and you got $50/SF; or, they decided there is no adjustment for bedrooms not accounted for by SF...that isn't something USPAP addresses. In fact, nothing in USPAP requires you to have 3 comparables. Why not just one?

 

[DWiley]

I saw that same sort of bias in a lot of complaints as well. IIRC, about 40% of the complaints we looked at were dismissed as being without merit. In fact, the state's attorney often asked me about that on the witness stand to establish that we weren't using "hired guns" to go on a witch hunt against appraisers.

 

[NEINAPPR]

File the complaint. They performed an appraisal in your state using Zillow as a data source and they are not licensed in your state. A technical review is one thing, but when they provided a new value (I assume without any geographic competency) and definitely without proper data sources they crossed the line and should be disciplined. I would also call the appraiser board in their state and see what they have to say about it (I would probably do that first).

 

[Zero]

PA requires an appraiser valuing PA property to have a PA state issued license, and the report to be signed with the credentials of the appraiser. So hopefully that Standard 3 review was performed under at least a temporary state license, and was signed in accordance with the state law requirements, else, it is a USPAP violation of competency.

Zing.

.

.

But at the same time, the PA AMC Act Specifically allows the use of out of state appraisers to do review work in PA:

"Section 7. Responsibilities and duties of appraisal management companies [63 P.S. § 457.27] (a) Conduct of reviews.--All appraisal reviews in this Commonwealth must be conducted for an appraisal management company by: (1) a certified appraiser in good standing in this Commonwealth; or (2) a certified or licensed appraiser in good standing in another state."

This was likely intended to allow Standard 3 Reviews for compliance (without opinion of value), required by the AMC act...but it doesn't specify.