Revised Report or 1004D?

[Alpine]

My sidekick and I completed an FHA appraisal for a manufactured home. The dwelling was missing both the HUD Certification Labels and the Data Plate. Based on HUD/FHA guidelines, I immediately informed the AMC/client for directive. After a week or two, client responds through AMC with: "Please proceed with the report subject-to the IBTS information being provided." So we did, "Appraised 'Subject to' client providing IBTS data as source for subject's Date of Manufacture, HUD Certification Label numbers, and Serial/Model numbers" along with relevant EA.

A few weeks go by, and the AMC sends the IBTS Performance Verification Certificate along with the following request: "The client has provided the IBTS report and it has been made viewable to you in the attachments section of the web order. Please complete any areas of the report needed. Please review and revise the report as appropriate." So, a revision request to change the original report, presumably to "As-Is", inserting the relevant HUD & Serial numbers, Date of Manufacture, etc.

In clarifying the request and discussing our fee with the AMC, their appraisal staff changed the order to a 1004D request, because (paraphrasing) "Any 'subject-to' conditions have to be addressed via 1004D", though I wonder if the change to 1004D was triggered by the fee involved. Whenever I've had this scenario in the past, I typically did not complete the report until the client provided the IBTS data, so it went into an "As-is" report. Completing a 1004D makes sense from one perspective, but the circumstance causes me to ruminate whether one should revise the original report with a new signing date (which presumes the client would want a simpler report with the now-available numbers in their respective locations), or whether the less-than-ideal 1004D (due to the 1004D language "Have the Improvements Been Completed...") is the logical/necessary follow-up to the "subject-to" condition of the report.

And yes, it's a "new" assignment/report either way, but I'm interested in the input of the brain trust regarding the best option.

 

[ctapraser]

My sidekick and I completed an FHA appraisal for a manufactured home. The dwelling was missing both the HUD Certification Labels and the Data Plate. Based on HUD/FHA guidelines, I immediately informed the AMC/client for directive. After a week or two, client responds through AMC with: "Please proceed with the report subject-to the IBTS information being provided." So we did, "Appraised 'Subject to' client providing IBTS data as source for subject's Date of Manufacture, HUD Certification Label numbers, and Serial/Model numbers" along with relevant EA.

A few weeks go by, and the AMC sends the IBTS Performance Verification Certificate along with the following request: "The client has provided the IBTS report and it has been made viewable to you in the attachments section of the web order. Please complete any areas of the report needed. Please review and revise the report as appropriate." So, a revision request to change the original report, presumably to "As-Is", inserting the relevant HUD & Serial numbers, Date of Manufacture, etc.

In clarifying the request and discussing our fee with the AMC, their appraisal staff changed the order to a 1004D request, because (paraphrasing) "Any 'subject-to' conditions have to be addressed via 1004D", though I wonder if the change to 1004D was triggered by the fee involved. Whenever I've had this scenario in the past, I typically did not complete the report until the client provided the IBTS data, so it went into an "As-is" report. Completing a 1004D makes sense from one perspective, but the circumstance causes me to ruminate whether one should revise the original report with a new signing date (which presumes the client would want a simpler report with the now-available numbers in their respective locations), or whether the less-than-ideal 1004D (due to the 1004D language "Have the Improvements Been Completed...") is the logical/necessary follow-up to the "subject-to" condition of the report.

And yes, it's a "new" assignment/report either way, but I'm interested in the input of the brain trust regarding the best option.

My bold,

The problem you would have with revising the original report is, the info you would add was not available as of the effective date of the report so the revised report could be misleading. Even though the signature date would be after the date you received the needed info, again the effective date would be before.

Do not change the original report and complate the 1004D, if that is the form they want it reported on.

 

[CANative]

You conditioned the appraisal on verification of original construction to the HUD code using an EA that it was.

The 1004D is the correct form to clear the condition. Technically the DEU could clear the condition without involving the appraiser but WTH? Make them happy and you'll get more business.

 

[Alpine]

Thank you, gentlemen. Agreed...

The initial revision request (from client) which morphed into 1004D request (from AMC) caused me to pause. Time will tell if I get a subsequent revision request: "Appraiser to revise...HUD/Serial numbers... Date of Manufacture..."

 

[sputnam]

The work involved would be about the same whether you revised the report or reported on a 1004D...so, the fee would be the same too. There is zero problem with revising the report, but you don't just change it...you add addendum comments explaining the reason for the revision, the date the new information was provided, changing the date of the report, etc.

 

[PhillyApp]

It seems that anything other than an as-is appraisal triggers a need for a 1004D anymore. If the 1004D is not present the investor will not buy the loan. I get some silly requests...

 

[VolcanoLvr]

I'd also suggest adding an additional signed Addendum page to the report, just before the 1004D.

On the additional Addendum page, put 'today's date' and state what the client requested and what you did to satisfy that request ... i.e., added the 1004D to the original report.

Then, include a statement in the additional Addendum that the addition of the 1004D is the only change made to the original report.

Sign the report with 'today's date', not the original signing date. The report Effective Date remains the same.

An appraisal report done on a GSE form is a federal legal document. Adding the additional Addendum page gives the client and any future reader (investigator) written evidence as to what was done to the report subsequent to its original submission.

Use this process any time a modification request to a report is made by anyone.

 

[JennStreyckmans]

Since this was ordered as a FHA loan it should not be completed on the 1004D. Mortgagee Letter 2009-51 states that manufactured homes using FHA financing must be provided on the Compliance Inspection Report (92051).

 

[huntercharlie]

Since this was ordered as a FHA loan it should not be completed on the 1004D. Mortgagee Letter 2009-51 states that manufactured homes using FHA financing must be provided on the Compliance Inspection Report (92051).

Additionally, FHA 2012 Q&A;

Can the 1004D be used in lieu of form HUD-92051 for manufactured housing?
No, manufactured housing, whether new or existing, requires the use of HUD form 92051. The 1004D Part B can be used only for existing site built construction (stick built or modular).

 

[RSW]

Since this was ordered as a FHA loan it should not be completed on the 1004D. Mortgagee Letter 2009-51 states that manufactured homes using FHA financing must be provided on the Compliance Inspection Report (92051).

Good catch! I wish more people would read the material available.