- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
I think you should try reading it, first.Should i email it to TAF?
I think you should try reading it, first.Should i email it to TAF?
Finally we agree (partly ) on something -...though USPAP FAQ says the inspection is included in what is considered contributing significant real property assistance- it is not just "me" /my personal viewpoint..
My objection is to the deceptiveness they are using to facilitate this- it is either an inspection or it is not if it is not. If they say it is not an inspection but rather data collection to avoid being disclosed as contributing per above,, then it should not be called an inspection in the appraisal nor to the borrower nor to the investors buying the loan. You expressed concern about similarity in appearance of 1004P to the 1004 form is not clear which is which, ( I do not recall your exact verbiage), this is along same.
"Hello Mr /Mrs Homeowner I want to make an appointment to do data collecting on your house. ...".What?" goes the homeowner. " I thought it an appraiser was coming out to do an inspection. What is data collection? Who is coming to my house for it? A RE agent? When you said a "licensed trained professional" would be coming over I assumed it was an appraiser"..
Being transparent would open up too many questions...and god forbid a borrower or other vested parties actually be able to figure out what is going on. The regulators seem to be on same track as they decided fee disclosures of splits between AMC and appraiser would be "information overload " and thus kept from a borrower (only those states whose boards require it have it)
How much would you want to bet they will instruct the person making appointment to use the term inspection, and inspection will be used on the appraisal report, yet otherwise call it "data gathering " to avoid significant appraisal assistance disclosures... If that is not spin then I don;t know what is,
I think you should try reading it, first.
The only movement that's been happening on opinions here is that you have conceded certain things of which you were previously sure.
I've already said in the past that I think it's a mistake for Fannie to depict the 1004P as being so similar to a conventional 1004 due to the point that most casual readers won't read the disclosures and will simply proceed on the erroneous assumption that they are the same and that the appraiser invariably *will* come to the same conclusions as if they had personally inspected.
You know and I know the 1004P will not replace the entire 1004 trade. What I think it might do is eat up that percentage of the easiest assignments that are the most profitable for appraisers. That's a very valid concern, but I don't see that as an appraisal standards issue. Nor a liability concern for appraisers so long as they make smart choices about which situations to hold out for the personal inspection and refraining from relying solely on whatever meaningless disclosures Fannie puts into their forms.
One way or another the issue we're facing right now was always an inevitability. It was always going to come about, just that same as the fallout from the massive oversupply the appraisal profession created for itself - and to which some idiots are (amazingly) still contributing to.
I am not "now" talking about the separate business aspects of the situation. I've been doing it all along. I just decline to conflate them as being the same thing or being even marginally related. The oversupply of appraiser productivity is far more closely related to the decline of your business interests than what is and isn't an appraisal.
As I see it our beef is with Fannie, not the ASB. It's their form that might lead to *some* users and some 3rd parties to not realize they are getting less from the appraiser in these assignments. The ASB and USPAP have nothing to do with it.
The bigger challenge here - which we seem to be avoiding - is that some of these primary and secondary market users apparently DO think that getting less from the appraiser is sufficient for these uses. They're apparently not that worried that the value conclusion might not be as reliable.
In other words, our real problem is with our users.