The Foundations Authority

[Bob Ipock]

Terrell,

I am not trying to argue! I do have a serious question.

In NC ALL appraisals performed by a trainee, licensed or certified appraiser must meet USPAP. That is state law. In addition, Fannie Mae, Feddie Mac and every other backer and buyer that I am aware of requires appraisals to be USPAP compliant.

My question is this. What are some examples of appraisals which would not need to be USPAP compliant, who would request such an appraisal, what would be some purposes and intended uses/users?

Obviously this is not an issue in NC, but I am curious as to why someone would want or accept an appraisal that was not USPAP compliant and why it would be perferred over a compliant one.


Bob

 

[bradellis]

Ter and Bob,

1. Ter- sorry about the AK. Still not clear on the license level, tho. You mean they took a minor step towards mandatory licensing by requiring that every appraisal must be done by at least this license level? FRTs would automatically be prohibited as fed law applies there.

2. Bob, quite true that every loan thru a bank that gets sold needs some type of valuation- but not all need appraisals. If an appraisal is ordered, your state gets to set the licensing rules. But, Fannie and Freddie, for example, run AVMs out of their data bases and many loans are made without appraisals and packaged into MBS's. And, neither Fannie nor Freddie are banks, so they get to set their own rules- just like a private investor.

Brad Ellis, IFA, RAA

 

[Terrel L. Shields]

Didn't take anything you said as argument Bob, just differences in state laws. Yes, a Registered Appraiser in Arkansas can prepare an appraisal for a private party so long as he or she does not certify that it conforms to USPAP. They can prepare an evaluation for a bank....again...so long as they do not certify that it complies with USPAP. These evaluations do not have to conform to USPAP if under $250K. . In fact, they can do a lot of things we cannot. Accept contingent fees for tax work, write a 1 page report, etc. etc. Despite its aim, the loophole in evaluations is that anyone who does bank evaluations can avoid the words "appraiser", "appraisal", and "USPAP" and still do evaluations for a bank without any license even the RA. States cannot trump Federal regulations on that regard. My nephew, a real estate agent, does many inspections of repo'd property similar to 2070s without any license save his salesmans. He can prepare CMAs for those bank customers to bracket its value; estimate simple repairs; then, to top it off, he bids paint and fix it jobs as a sideline business. Banks with repo'd property frequently call upon him to make simple repairs to facilitate a sale. Sometimes he even gets the listing, though a lot of local banks seem to be marketing their own properties without Realtors. It sounds inherently conflicted but it works.

Because many reporting forms reference USPAP most of the RAs cannot prepare a report with a URAR / FNMA certification. But if the RA wants to get credit towards certification, they must comply with USPAP, thus they must have a co-signatory of a licensed or certified appraiser. Consequently, I doubt that more than a handful of appraisals prepared by RAs do not [attempt to] comply with USPAP.
ter