Reviewer's name withheld

[Mark Bets]

I'm being presented a field review of an appraisal I completed and the page with the reviewer's name is missing. In fact, pages 3 and 4 are both missing. Isn't that against USPAP standard 3-3?

I know that the reviewer might not have been given my name and that is allowed, but if I'm not privy to the reviewer's name, why should I care what he has to say? More importantly, if he doesn't have to follow USPAP, why should HE care what he has to say?

 

[TC]

Because He is all powerful and you only work for a living.


TC

 

[Tim Hicks (Texas)]

Maybe the company that ordered the review removed the reviewer's information. I bet they have a full copy, but you are on the need to know basis.

 

[hastalavista]

Mark-

First, welcome to the forum; I see this isn't your first time up but close to the first.

Second, your question is very relevant to a lot of discussion that has taken place on the forum regarding reviews, SR-3, Review SOW, and AO-20.

So, let me give you summary version of what I think:

1. The review is for the lender's benefit.

2. The review may have a SOW that is totally different from yours.

3. You are not entitled to see the entire review (although I wish everyone would, because it may make things a lot clearer as to what was and wasn't done, and why). In fact, you are not entitled to see it at all (at this stage; if you made a complaint against the reviewer, at some stage, if appropriate, you probably would be able to see it).

4. You should care less who the reviewer is; it shouldn't matter.

5. You do not have to respond to the review. However, if you don't, the lender doesn't have to accept your appraisal (they don't anyway, but will be less inclined to do so with a "no response" if that is what they are asking).

6. Reviewers are like origination appraisers: Some are good, some are mediocre, and some stink. You may have gotten a rotten one; if so, your addressing the review should be relatively easy. On the other hand, there may be a legitimate question that the reviewer has that isn't adequately addressed/or an item that isn't adequately explained in the original report. You didn't make a comment as to your feelings of the validity of the reviewers comments, so I don't know if you feel there are any legitimate questions. Remember: You know what you were writing about in your report, so when you read it you understand what you are trying to say. Not all reports transmit what the writer knows to the reader (who, it should be assumed, doesn't know what you know).

7. The function of the origination appraisal in a mortgage finance transaction is to provide a user with an opinion of value on a property. That opinion is going to be used to make a lending decision. The opinion needs to be communicated in a manner that is credible. The review function is supposed to insure that origination reports are credible; as a rule, this means that their values are reasonable.
If any piece in this chain is weak (poorly written or supported origination appraisal, poorly trained underwriters, poorly trained reviewer), the system stops the process.

So, your appraisal has been flagged because something is wrong or questioned. That question or "wrongness" can be your appraisal, the UW process, or the reviewer.

If it were me, and it wasn't my appraisal that caused the system to stop, I'd want to point that out as best I could. If there was some deficiency in my report, I'd want to correct it. If I felt it was the review that was wrong, based on USPAP compliance, I'd file a complaint. However I'd want to be very sure of the validity of my complaint if it is USPAP related; It would be professionally embarrassing as well as calling my USPAP competency into question if I lodged a USPAP complaint that had no basis. Your posting here suggests to me you want to be sure, too!

My 2-cents. Good luck.

To everyone else reading this thread and not directly related to Mark's specific issue: In general, are we not seeing more "review" posts now? Does it not seem that more and more reports are going to review? Sounds like I've heard this prediction (now, perhaps no longer a prediction but an observation) before?

 

[Michigander]

Very well written response Denis, and yes, I believe the forum has moved towards many more posts on reviews, as would be expected in a down market such as this.

 

[Richard Carlsen]

I'm being presented a field review of an appraisal I completed and the page with the reviewer's name is missing. In fact, pages 3 and 4 are both missing. Isn't that against USPAP standard 3-3?

Denis beat me to it.

Just because your report is the subject of a review does not mean that you have any right to it. Ever hear of Intended User and Intended Use? The original author of the reviewed report is neither.

Responding to questions raised in a review have nothing to do with who did the review. That's personal. You are to defend your report and nothing else. My only run-in on a review was from an appraiser who did not like me "coming into her territory". I could not attack her for such a parochial attitude but I could defend my report showing where I was right and the reviewer was wrong.

Defend your report; don't attack the reviewer.

 

[George Hatch]

Denis' comment about there being more questions about reviews is spot on. The markets are cooling off and in some cases are in decline. When the markets are on the increase appraisals represent a checkbox in the loan file for these lenders because they know a rising market will cover a lot of problems. However, when the market is on the drop the appraisals - and appraisal reviews - become a lot more important to them.

The days of the vanilla appraisal report that raises no flags and can be scanned at a glance are past us.

With that in mind, many appraisers should be beefing up their appraisal reports. By that, I do not mean adding 20 pages of boilerplated addenda, but I do mean including some meaningful explanations for why we are doing what we're doing. You should assume that most or all of your reports are going to be reviewed by someone outside of the production pipeline, and that if they have any questions about local market conditions, subject property attributes or comp selection they will be asking those questions.

Especially with comp selection, if you know of comps that would show up on a reviewer's search but which are not suitable as being "the most similar, proximate and recent" for your appraisal you should deal with them in your report. Don't assume that a reviewer is going to ignore them just because the comps you do use generally fit within the "standard" restrictions of 1 mile and 6 months or whatever you normally use in your area.

In this environment it is quicker to do it right than it is to do it fast.

 

[Brad Ellis]

Mark,

Denis and George have really nailed this. Pay close attention to their advice- they are leading you down the correct path.

Brad

 

[Tim Hicks (Texas)]

Is it possible that the original report was not detailed enough or vague in nature? Were there plenty of explanations about the improvements and upgrades?

You would be surprised how many reports I review that are "vague" in nature that list the home as "updated" or "highly upgraded" but then don't list any of the updates or upgrades or explain anything. Then they use comparable sales with distressed hard woods, custom paint, granite counters, marble and nowhere in the report does it say the subject has these things. Or they avoid the sales in the subdivision without explaining why. Or they give a high dollar adjustment to a pool or barn, but never say anything about the quality of this improvement.

Are you getting the picture?

 

[Hank Henry]

I agree Brad, but one other thing, as George pointed out, the market
is changing in some areas. Pary close attenton to the top two lines on page 2 of the URAR and make sure they are consistent with the check boxes on page one. The simple laws of economics- supply and demand are very good concepts to keep in mind.