Scope of Work

[Fred]

Brad

No modifications are allowed.

We all have to choose sides in the tug of war. Fannie says no changes.

The ASB says:
”…Form 1004 requires supplementation to clarifywhich parties the appraiser is identifying as Intended Users.”

About 40 state bourds say:
“…regardless of Fannie Mae’s position that “modifications or deletions to thecertifications are not permitted,” it is the appraiser’s responsibility to comply with USPAP. Therefore, appraisers must provide supplemental clarification in their appraisal reports regarding specifically who the intended users are.”

If appraisers had anything resembling an umbrella organization, it would be time for the lawyers to seek an injunction against Fannie.

 

[Thomas N. Morgan]

Right on George and Steve:

One day, Fannie Mae will get their final come-uppance.

Back to Scope of Work. I started hearing about scope of work sometime around maybe 1976 in the SREA. The advice then was you should have a Scope of Work in your reports. That's as far as it got, then. Nobody seemed to do it. even though they had heard about it. Why did the idea take so long to be generally recognized?

Even now, there seems to be confusion about what it is. Why should statements about for whom the report was prepared be in a Scope of Work?

I think someone here wrote that if the reader can tell just by reading the report what you did, how you did it, you don't need a separate, canned Scope of Work statement.

 

[Otis Key]

I have come to believe that Fannie's failure to provide an updated appraisal policy is neither an accident nor an oversight. I think they know that once they formally commit these policies to their selling guide that they will have painted themselves into an obviously indefensible position. That position will be disassembled by the first E&O attorney who argues the case in court. All that attorney has to do to research their argument is do a search on this forum and hit the print button - it's all here.

I think Fannie is playing a waiting game and hoping that the common usage of the forms for a couple years will establish some sort of precedence of reasonableness. It won't, of course, because the conflicts were pointed out before the forms came online and have been routinely and uniformly criticized by everyone since then.

George, I also agree with you but I also think that an experienced and knowledgeable attorney can also chew up the current form because of the lack of a current policy and due to the conflicting terminologies and statements. The best thing that fannie could do now is generate a current policy statement for all to know.

 

[Pat Butler]

We can have it both ways. Fannie has us certify in #3 that we are adhering to USPAP. Therefore, do whatever is necessary to comply with USPAP even if it conflicts with other provisions on the cert pages. That's their problem. They've created an impossible situation and I'm going to comply with the higher authority- my state's requirements and USPAP.

 

[Steve Owen]

Right on! George and Steven

Heidi,

The Fannie forms- to be used for work that is intended to be Fannie compliant- has the scope of work built right in. No modifications are allowed.

The only modification Fannie allows is the specific wording that they agreed to with the AI as regards Intended users.

If you have a non-Fannie assignment you can easily use the old forms and certs and they can be modified in pretty much anyway you see fit.

Brad

Point of order, Brad. I believe that it is the certifications that Fannie will not allowed to be changed. And, even there, they allow for changes that are required by membership in an appraisal organization or by regulations, so long as those changes add to the certifications and do not take anything away.

Scope of Work: you must do at a minimum what is pre-printed on the form. Otherwise, you are free to add to the scope of work, as needed for the individual assignment.

(Keep in mind, however, that Fannie will not accept EA's or HC's except for those that go with their pre-printed check boxes. Therefore, it is my NSHO that it is virtually impossible to do an exterior only appraisal for Fannie.)

 

[Otis Key]

Point of order, Brad. I believe that it is the certifications that Fannie will not allowed to be changed. And, even there, they allow for changes that are required by membership in an appraisal organization or by regulations, so long as those changes add to the certifications and do not take anything away.

Scope of Work: you must do at a minimum what is pre-printed on the form. Otherwise, you are free to add to the scope of work, as needed for the individual assignment.

(Keep in mind, however, that Fannie will not accept EA's or HC's except for those that go with their pre-printed check boxes. Therefore, it is my NSHO that it is virtually impossible to do an exterior only appraisal for Fannie.)

Point of order Steve

Fannie, or more specific - Joe Minnich - won't allow you or me or anyone else to change the form or certification. However, the form and/or certification also states that we comply with USPAP. SOooooooooooooooo, in that case, THE CASE is closed. We can supplement the form and add additional statements need to comply with USPAP.

 

[Jo Ann Meyer Stratton]

The paragraph regarding #23 that Fannie Mae and the AI hammered out was only a suggestion--not a requirement. A lot of people seem to forget that specific point. They read the memo, jumped on their horse and took off flying that "oh Fannie REQUIRES that statement" without really reading the entire memo and deciphering what it actually said. Now the repercussions are that somebody heard from another underwriter who heard from an appraiser who heard from a loan processor who heard from a file clerk who heard a conversation in the hall that there is now a "required Fannie Mae statement". Read the actual memo--think about the wording in that memo before and after the famous paragraph. Until they reword the memo and place it in their selling guide it is not "required".

 

[Brad Ellis]

To the "point of order" folks,

Yes- sorry about that. My intent was to note that we cannot reduce the scope of work for Fannie- but we can expand it.

Whatever your feelings about Fannie and cert 23 and other stuff, the simple fact of the matter is that appraisers who put unacceptable restrictions in their addenda will see them rejected- if someone is paying attention.

As Joann notes, the restriction allowed by Fannie in the intended user section is optional, not mandatory.

Brad

 

[Brad Ellis]

Steve,

On the drivebys, yes I concur. Only under the most unusual of circumstances could a driveby be completed for Fannie, professionally and accurately anyway.

And lots of exposure on that one.

Brad

 

[Francois K. Gregoire]

The paragraph regarding #23 that Fannie Mae and the AI hammered out was only a suggestion--not a requirement. A lot of people seem to forget that specific point. They read the memo, jumped on their horse and took off flying that "oh Fannie REQUIRES that statement" without really reading the entire memo and deciphering what it actually said. Now the repercussions are that somebody heard from another underwriter who heard from an appraiser who heard from a loan processor who heard from a file clerk who heard a conversation in the hall that there is now a "required Fannie Mae statement". Read the actual memo--think about the wording in that memo before and after the famous paragraph. Until they reword the memo and place it in their selling guide it is not "required".

Jo Ann,

You are correct the statement is a suggestion. Please keep in mind you state appraisal regulatory board may have something to say about the need/requirement for a clarification of intended use/users. See the AARO Resolution at the link below:

http://aaro.net/pdf/AARO_2005-10-10_FNMA_Resolution.pdf