Doug
First, the question is why does the new lender need to have his name in the appraisal report? Federal regulations say that a "regulated instituiton may accept an appraisal that was prepared by an appraiser directly engaged by another financial institution if the appraiser has no direct or indirect interest, financial or otherwise, in the property or transaction; and, the regulated institution determines the appraisal conforms to this part (of the FFIRA rules) and is otherwise acceptable. See USPAP 2002 AO-10 lines 38-52. This does not require a change in the text of the report, and not even an entirely new certification page, just the comment that you have no interest in the new party to the transaction.
In short, lender a can get the report released from lender B and use it, all they need from the appraiser is a certification that he has no direct or indirect interest, financial or otherwise, in the new party to the transaction. Of course, this certification would have a different date than the original report, and makes the report "messy" for the underwriting down the road.
What the lender is really asking you to take care of the adminsitrative end of this issue for them (get the release), then "clean up" the work for them so they do not have to provide the explanation for different dates and get your certification at the same time. What they would like is for you to do the work for free, or at nominal cost.
Aside from working for free which is in general a bad business practice, the problem with the appraiser "readdressing" by merely changing the references to the client in a prior report , even with approval of the original client, is that it would be misleading, ie, there is no trail of what really happended. Clearly, the very fact that you reissue the report without changing the date of the signature when in fact you would be sending out the report on a different date would be considered misleading to an investigator following the paper trail.
So you then have to change the signature date of the report, then you are posed with the issue of resolving the issue is this now an update with a new date of value, and if so, has there been any new data that should be included or is it a retropsective appraisal. If it is a retrospective appraisal, Statement 3 kicks in and poses some additional requirements about reporting dates.
Am I being to picky with this issue? If you recognize that some loan officers and some borrowers are not acting ethically, and that these yahoos are just setting the appraiser up to take the fall, it is not too picky.
Posters on this forum have had different solutions to the problem, some are good and others not so good. The most common solution is to change the lenders name in all the appropriate places with a disclosure in the report. Those suggestiong this as a simple fix does not really address the effective date of value and the date of the report conflict.
Personally, I think the best thing is to tell the new lender to get the release, have the new lender send you a copy for your workfile along with a request for a certification. You can then respond in a letter which states the original report, the original client, the new client, and a simple certiffication that states that you have no direct or indirect interest in the new client, along with an admonition that the lender is supposed to attach the letter to the original report.
Is this cumbersome and a lot of paper work? From your perspective, it is only a one page letter, I say that is better than having to reproduce a new report. Have template made up, and all you have to do is plug in the pertinent pieces of information and print it. Should not take 5 minutes since the lender has to do the phone calls and get the release and write you the letter. Is it extra work for him, yes, but heck, he is the one making the bucks off the deal. Is there some work for you, yes, but you should charge for it. Further, it is better to do it the right way than possibly getting unintentionally caught up in some fraudulent scheme.
Just remember, most of the time when you are asked to do "something simple" for someone else, it is because they found it to be more difficult than what they want to undertake. So charge a goodly amount for the hassle. If the lender wants you to do all the leg work, fine, then you should charge more.
You can take the short cut like many and just readdress the report based on the phone call, it is your choice. But....
Regards
Tom Hildebrandt GAA