Should I file complaint with Appraisal Board?

[Lysander in Charlotte]

I have an appraisal report of a Charlotte property done by a Charlotte AMC appraiser and a MARI review completed by a Raleigh appraiser. The reviewer renders a value opinion. The copies were sent to me by a pre-HVCC great client who was just venting. I have no status in the situation as I was neither the appraiser nor the reviewer. I have appraised the same property in the past. I know neither the appraiser nor the reviewer.

I've not delved into the report or review enough to have an opinion regarding the merits of each. I does make me angry that a Raleigh reviewer would offer a value opinion on a Charlotte property without visiting the property. The MARI review states that no inspections were made. Isn't this a clear USPAP violation?

I'm contemplating filing a complaint with the Appraisal Board. The complaint would be simply that the reviewer rendered a value opinion without geographic competence or documentation. Part of me says, don't do it. You don't have a dog in ths fight. Conversely, this reviewer is so far out of bounds that she needs to be removed.

Should I proceed?

 

[stefan olafson]

Depending on the professionalism of the Board you are taking the chance of getting placed on their radar as a troublemaker. Way back in the early 1990's I made a conscious decision to report blatant violations to the board. My license was revoked in 2003 partly in response to the extra work I was piling on the board members.

Be Careful!

 

[Bob Ipock]

There is no USPAP requirements for inspection of the property....unless the certification says an inspection was performed.

Rendering an opinion from 175 mile away is stupid....even if not a violation.

The Fannie Mae 2055 Field Review DOES require "a visual inspection from at least the street".

The common "Desk Review" forms do not require any visual inspection.....unless the appraiser says he did.

 

[Bob Ipock]

Caution: The appraiser may well have geographic competency thru frequent Charlotte appraisals or some other factor unknown to you. I say this because I know of a case where the reviewer lived 100 miles away....but did in fact have market competency.

 

[Lee Lansford]

[.......................

 

[Lee Lansford]

...

Should I proceed?

As I read your words, I see (correct me if I am wrong) more suppositions on your part that deficiencies exist than I see concrete evidence that something(s) specific is (are) deficient.

 

[Smokey Bear]

First you need to look at the reviewer's scope of work.........

 

[Lysander in Charlotte]

As I read your words, I see (correct me if I am wrong) more suppositions on your part that deficiencies exist than I see concrete evidence that something(s) specific is (are) deficient.

Lee, I can't disagree with your statement. I stated all I know. Hence, the hesitancy to proceed. On the surface, this a personification of many of the things that are wrong with my profession. You have non geo-competent appraiser in Raleigh rendering a value opinion on a property in Charlotte without the required due diligence, all for probably an irrelevant $75. The bank likely had no local appraiser that would accept such an assignment. If I do nothing, the bank and this appraiser will keep doing what they're doing. That said, I'm inclined to do nothing. The risk are personal while the rewards a collective and negligible.

Bob, Assuming no geographic competence, this is a serious USPAP violation. Right?

 

[Bob Ipock]

Yes, it would be a violation of The Competency Rule.......if this was a field review and the reviewer was unfamiliar with the market.


If this was a Desk Review....no geographical competency is specifically required or assumed under the limiting conditions and appraisers certification (on most deck review forms).

SCOPE OF REVIEW: p* The scope of this review is limited to the information being provided by the original appraiser, and is to form an opinion as to the apparent adequacy and relevance of the data and the propriety of any adjustments to the data; form an opinion as to the appropriateness of the appraisal methods and techniques used and develop the reasons for any disagreement; form an opinion as to whether the analyses, opinions, and conclusions in the report under review are appropriate and reasonable, and develop the reasons for any disagreement.

Which was it? Is there a form # on the bottom?


Others may disagree and say that geo. cmp. is always required........but that has not been tested/required of a desk review which is based solely on the information included in the appraisal under the review.

If your review of the review indicates any kind of incompetency or lack of credibility....file a complaint. There is simply no other way to address rogue appraisers.

 

[Bob Ipock]

From Desk Review:


P*CERTIFICATION: p* The reviewer certifies and agrees that, to the best of his/her knowledge and belief:

1. The facts and data reported by the Reviewer and used in the review process are true and correct.

2. The analyses, opinions, and conclusions in this review report are limited only by the assumptions and limiting conditions stated in this review report, and are my personal, unbiased professional analyses, opinion, and conclusions.

3. Unless stated elsewhere, I have no present or prospective interest in the property that is the subject of this report and I have no personal interest or bias with respect to the parties involved.

4. My compensation is not contingent on an action or event resulting from the analyses, opinions, or conclusions in, or the use of, this review report.

5. My analyses, opinions, and conclusions were developed and this review report was prepared in conformity with the Uniform Standards of Professional Appraisal Practice.

6. Unless stated elsewhere in this report, I did not personally inspect the exterior subject property.

7. No one provided significant professional assistance to the person signing this review report.


Please don't misunderstand me......if the appraiser or reviewer is incompetent (in any manner) ten they should not accept or perform the assignment.