8)
HUD is an intended user. They have never claimed to be "The Client". I suggest you contact Brent Pick at REAC. However, VA considers themselves to be the client. However, the VA Regional Office in Roanoke, VA said that if a lender wants an apprailsal transferred to another lender, they need no approval from VA. However, if they insist on having their name on the report(VA does not require it), then the lender should get the OK from lender the appraisal was done for, and request the appraiser change the client name, after providing the appraiser with the release, so the appraiser can comply with USPAP.
HUD has never stated, anywhere, that they have any jurisdictional exception to any part of USPAP. If you read the handbook carefully, you will see that is the case. They consider the lender the Client and themselves(HUD) as an intended user. You must follow USPAP as I have previously pointed out by referrencing the appropriate parts of USPAP. BTW, both VA and HUD does not prohibit charging for such reassignment.
Don