Revision request vs update vs new appraisal

[BRCJR]

My state law allows an Appraiser to do Evaluations. The opinion opined is not an appraisal by law and definition.

The post 36 was a copy and paste for educational purposes. Some got it some did not, obviously.

I never one time indicated I ignore USPAP. Where in the heck are you coming up with such conclusions?

 

[Sadie]

My state law allows an Appraiser to do Evaluations. The opinion opined is not an appraisal by law and definition.

The post 36 was a copy and paste for educational purposes. Some got it some did not, obviously.

I never one time indicated I ignore USPAP. Where in the heck are you coming up with such conclusions?

Your posts and USPAP. BTW federal law trumps state law, Reread AO 13. I take it you haven't.

 

[Dublin ohio]

BTW federal law trumps state law

Which Federal law would that be?

 

[BRCJR]

Which Federal law would that be?

Good question...let's see if you get a reply.

 

[BRCJR]

Your posts and USPAP. BTW federal law trumps state law, Reread AO 13. I take it you haven't.

Your assumption is incorrect. I have read AO 13. By the way, it is not USPAP. Maybe someone other than me does not have a clear understanding of what USPAP is and is not.

 

[BRCJR]

Your posts and USPAP. BTW federal law trumps state law, Reread AO 13. I take it you haven't.

By the way, Interagency Appraisal and Evaluation Guidelines ARE codified into federal law........

• Interagency Appraisal and Evaluation Guidelines (IGs): These guidelines differentiate evaluations from appraisals. According to IGs, evaluations are needed when a transaction qualifies for certain exemptions (such as the appraisal threshold exemption for mortgages under a specific amount). However, many lenders still choose to order appraisals even when evaluations are an option.
• USPAP: The Uniform Standards of Professional Appraisal Practice (USPAP) doesn’t specifically address evaluations. However, Advisory Opinion (AO) 13 states that if an appraiser writes an evaluation, that evaluation must conform to USPAP, effectively treating it as an appraisal.
• Differences Between Evaluations and Appraisals:
  • Highest and Best Use: Appraisals require an analysis of the property’s highest and best use, while evaluations have no such requirement.
  • Rationale and Logic: Appraisals must include a summary of the analysis’s logic and rationale, whereas evaluations have no such requirement.
  • Reasonable Exposure Time: Appraisals analyze reasonable exposure time; evaluations do not.
  • Format: Appraisals come in two formats (Appraisal Report and Restricted Appraisal Report), while evaluations have no specific format.
  • Certification: Appraisals require a signed certification; evaluations do not.
  • Credibility and Reliability: Appraisals must be credible (worthy of belief) per USPAP, while evaluations must be reliable (not specifically defined by IGs)2.

1. Who Can Perform Evaluations?: According to IGs, qualified individuals who can perform evaluations include appraisers, real estate lending professionals, agricultural extension agents, or foresters. These individuals must possess the necessary education, expertise, and experience, be capable of producing an unbiased opinion, be state certified or licensed, and have no direct or indirect interest in the property transaction2.

Remember, though, that the specifics can vary from state to state. So, if you’re inquiring about a particular state, it’s always a good idea to check the local regulations!

 

[BRCJR]

Your posts and USPAP. BTW federal law trumps state law, Reread AO 13. I take it you haven't.

Link to Federal law regarding appraisals and evaluations.

Hope this helps you to have a better understanding of both.

https://www.FDIC.gov/news/financial-institution-letters/2018/fil18062.html

 

[Sadie]

Your assumption is incorrect. I have read AO 13. By the way, it is not USPAP. Maybe someone other than me does not have a clear understanding of what USPAP is and is not.

No the AOs are not part of USPAP, but they are an expert intrepretation of applicable portions of USPAP, which are cited in the AO. You can ignore them if you want, but be ready to explain why your interpretation of the applicable portions of USPAP is superior to the AO. And TBH, its really just us appraisers who care about the minutiae of USPAP.

 

[Sadie]

Link to Federal law regarding appraisals and evaluations.

Hope this helps you to have a better understanding of both.

https://www.FDIC.gov/news/financial-institution-letters/2018/fil18062.html

USPAP was adopted by Congress and compliance is required for state licensed and state certified appraisers involved in federally regualated transactions. Individual state laws is how it is enforced at the state level. So the states at a minimum must have in laws that conform to USPAP into their code, they can go farther. By federal law, I meant what is required at the federal level (USPAP) is superior to a contradicting or lesser state requirement/law.

 

[BRCJR]

USPAP was adopted by Congress and compliance is required for state licensed and state certified appraisers involved in federally regualated transactions. Individual state laws is how it is enforced at the state level. So the states at a minimum must have in laws that conform to USPAP into their code, they can go farther. By federal law, I meant what is required at the federal level (USPAP) is superior to a contradicting or lesser state requirement/law.

Is an Evaluation a federally related transaction?