This VA appraisal I'm reviewing is one of the worst I've read. Is there any way I can report this to the VA?

[glenn walker]

The very reason we have so many bad appraisers is because gutless appraisers won't file complaints. You don't get to be the judge or jury. When you see a serious violation, you are obligated to file a complaint. You simply send in a complaint with a copy of the appraisal. Take a highlighter and mark everything you think the board needs to look at. If you see someone shoplifting. or stealing someone's property do you just turn your head?

Everyone needs to read USPAP. Page 7, lines 196-197. We all have an obligation to report appraisals we come across that are "misleading or fraudulent". Numerous people have been sent to prison because an honest appraiser filed a complaint.

Not going to argue but Lenders have legal council and they know what they are supposed to report or not report. A Independently hired Reviewer Client Engages him to do the review and send it back to them with his findings. At that point the reviewer has not stepped outside his engagement with Client and scope of work. Some reviewers often stray from the goal and start appraising the appraiser and not the appraisal.

When doing forensics for the Mighty Bigger Bank USA during the mortgage meltdown the team consisted of reviewers and also teamed with a legal department who made decisions on what may or may not be USPAP issues or if they should file a complaint with a State Board. My advice is let the Bank-Lenders legal deal with it thats what they get paid for . This is especially True when the Reviewer has opined a new or different value now he owns the new value and he may be asked for a copy of his review- a complete work-file and guess how many Reviewers "? Unintentionally Violated USPAP Review Standards and now there both slapped with USPAP Violations.

 

[JeffSH]

I would never make a statement like "the appraisal quality is below average and the analysis is unreasonable." We are supposed to demonstrate in the review step by step what, if anything, is deficient about the appraisal and analysis. The client can decide for themselves subjectively how bad they think the OA is.

This makes absolutely no sense. Banks hire us for our opinions. The bank cannot think the report is objectively bad until we tell them so. It's my job to review this appraisal. Why wouldn't I fully elaborate? Just giving the client a list of factual differences and a new sales grid is lazy. I make similar statements when I review good appraisals.

"The appraisal quality is above average. The analysis is well detailed and consistent. The comparable selection is good. Etc"

 

[George Hatch]

Why is it lazy? The primary manner in which an SFR appraisal goes bad is in the mischaracterization of the facts about the subject attributes, the comparables' attributes or the assertion that these are the most comparable sales data. When you cite a factual discrepancy and attribute the outcome of the appraisal to the use of that factual discrepancy that takes all the subjectivity and opinion and style arguments out of the equation. There IS no rebuttal to a factual error. It's also the most dispassionate way to fixate on the content of the report as opposed to the actions of the appraiser.

That list you cited in the OP and your alternative SC analysis is all it takes to make your case. I wouldn't have even bothered with the bathroom v deck adjustment. The bigger problem is the lack of more recent sales in a dynamic market with no consideration for those market conditions. Those market conditions being part of the subject's attributes.

 

[glenn walker]

This makes absolutely no sense. Banks hire us for our opinions. The bank cannot think the report is objectively bad until we tell them so. It's my job to review this appraisal. Why wouldn't I fully elaborate? Just giving the client a list of factual differences and a new sales grid is lazy. I make similar statements when I review good appraisals.

"The appraisal quality is above average. The analysis is well detailed and consistent. The comparable selection is good. Etc"

Judge -- Sir- can you define for us what above average quality means ? What do We measure that standard against ? Your Standards ? Have we now stepped outside what other reviewers or peers would do . You have lots of opinions and potential accusations but now maybe its time we have your review reviewed by a real expert and a AQB Qualified USPAP Expert. Will your review be deemed "above average " Super Good-Fantastic and did your Client give you permission and authorization to send their review to outside people or Boards without them knowing about it. Yes you can do that but you are now on your own.

 

[Tom D]

when i felt like doing a review long ago, never not now, i would just add the missing info to the review. hey, no 3 yr history, here it is. if the comps looked confusing i would add a comp or two to un confuse the range. you are more liable for the review than the original appraisal, so you better be dead right with your work file. as long as the value was fine, and there wasn't any outright fraud. i accept the stupidity and just give more better info when needed to un confuse.

 

[JeffSH]

This debate we're having all boils down to whether value is objective or subjective. Value is not subjective. It's a range. But it's not just an opinion.

We've all reviewed crappy reports with 3 comps that somehow magically arrive at the correct value. Those appraisals are below average in quality.

My definition of quality is based on the reports of my peers. This sure as hell isn't the first appraisal I'm reading

 

[glenn walker]

Can a Appraisal Reviewer be sued ? Yes if any accusations or different value conclusions are unsupported or found found to be false or unsupported . If THAT Original Appraiser is removed from a fee panel because of a unfounded complaint filed by the Lenders reviewer he may have a Civil Case and unless reviewer can prove critical assertion with substantial evidence, the reviewer can risk being sued for libel or slander and monetary loss and damaged due to losing work and income. RARE -YES but it does happen yes usually when the reviewer has stepped on someones toes who has money or a lot of free legal council and hen his Client also turns on him. A reviewer may have one of the most potentially dangerious jobs in the appraiser profession especially when opining new and different values.

 

[DWiley]

, the reviewer can risk being sued for libel or slander and monetary loss and damaged due to losing work and income. RARE .

The best defense against a libel or slander claim is to limit the appraisal review to the actual report. Typically, reviews should limited to the report content, not the appraiser.

Example: Rather than saying/writing, "The appraiser did not apply time adjustments..." say/write, "The adjustment grid in the appraisal report contains no adjustments for date of sale....."

 

[Tim Hicks (Texas)]

Honestly, I did many reviews for Freddie Mac and Fannie Mae in the early 2000's. Stick to the facts and don't issue opinions about the quality of the appraisal or USPAP violations. The individual state boards enforce USPAP and make the decisions on USPAP violations, not a review appraiser, not the lender. Follow the form 2000 and answer objectively and truthfully like Danny says above. Let the lender submit it to the state board. Do you have permission to discuss the review with anybody else? Could you submitting it violate your lender/client agreement? Stick to the assignment conditions and hopefully your review will not possess any USPAP violations of its own.

 

[glenn walker]

The best defense against a libel or slander claim is to limit the appraisal review to the actual report. Typically, reviews should limited to the report content, not the appraiser.

Example: Rather than saying/writing, "The appraiser did not apply time adjustments..." say/write, "The adjustment grid in the appraisal report contains no adjustments for date of sale....."

Very Good A True Professional Reviewer Among Us--
There are Numerous ways of saying something without making it look like you have strayed from Reviewing the Appraisal to Reviewing The Appraiser. We used to cringe at some of the things reviewers would say in their reports. The real Wackos- He committed fraud shows 15 USPAP Violations, the report to be Sent to State immediately, he needs removed from the fee panel, it went on and on. The Worst were what we called the Review Zealots who believed their calling in life was to get any and all bad appraisers off the streets. The funny part is we often reviewed their reviews sometimes just for fun and they were as bad or worse then the original appraisers who they were recommending being turned into the State Boards.