Donald wrote:
The problem with lender clients is that they really don't need an appraisal. What they need is our opinion about the appropriatness of the loan that they are proposing on the property.
That opinion about the appropriatness of the loan that they are proposing on the property could be viewed as a consulting assignment and not an appraisal, right?
What the lender wants the appraiser to do when requesting pre-comping or stopping the appraisal is ultimately to provide a consulting service that will only turn into an appraisal order when the consulting service provides grounds for covering a needed loan amount.
I don't think a single appraiser who accepts an appraisal order perceives himself or herselfas providing a consulting assignment simultaneously with performing an appraisal.
Standard 4: Real Property Appraisal Consulting,Development reads
[Comments on Standard 4-2 (f)(ii)
"If the opinion of value is from an appraisal developed by the appraiser performing the real property appraisal consulting assignment, the appraiser must complete the steps set forth in STANDARD 1 for the type of appraisal (Complete or Limited) pertinent to the purpose and intended use of the opinion of value to be developed. The appraiser’s appraisal-related scope of work must, at a minimum, include those steps necessary to comply with Standards Rules 1-2©, (d), and (e) and, given the purpose and intended use of the appraisal in an analysis supporting the appraisal consulting assignment results, the research, verification, analysis, and reconciliation steps necessary to comply with Standards Rules 1-3, 1-4, 1-5, and 1-6 as applicable."
But here's the rub: in Standards Rule 5-3 (Real Property Appraisal Consulting, Reporting), the certification must state:
"– I have no (or the specified) present or prospective interest in the property that is the subject of this report, and I have no (or the specified) personal interest with respect to the parties involved.
– I have no bias with respect to any property that is the subject of this report or to the parties involved with this assignment.
– my compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal."
There you have it.