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Transferred Appraisal Report

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Eric C

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Jul 25, 2006
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Certified Residential Appraiser
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Florida
Hi guys... I haven't been on here for a while so I'm not sure if this has been discussed already.

as you know lenders are now able to use an FHA appraisal that was done for a different lender without having to change the "client" on the report so what do you when this new lender asks for "additional comments" on the report?
 

BRCJR

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Tell them the request must come from the original lender and will be submitted back to the original lender.
 

leelansford

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Illinois
See post #2. I agree. Correct answer.
 

Howard Klahr

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as you know lenders are now able to use an FHA appraisal that was done for a different lender without having to change the "client" on the report
Lenders have always been able to use an FHA appraisal that was done for a different lender without having to change the "client" on the report. The report is transferred from the original lender to the new lender and does not involve the appraiser at all to accomplish this process.

this new lender asks for "additional comments" on the report?
The big caveat to the transfer process is that the new lender must use the transferred appraisal report "As is" without modification. In the event the "new" lender wants changes to the original report you are not allowed to make any on their behalf. As noted above by BRCJR the original lender must process and and all change requests as the original client for FHA reports due tot the fact that appraisal FHA reports remain with the property for a period of time (6 mos) and be appropriately documented

For non-FHA assignments, any change requests would require preparation of a new report. In the event this occurs the appraiser would be required to disclose the prior service of the initial report under USPAP however.
 

glenn walker

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The original poster should contact their HOC and get advice . Our HOC used to tell us that when a case number was transferred to a new lender the name of the lender did not have to be changed but the assigned FHA lender was our client along with FHA/HUD and when the new lenders FHA Underwriter reviewed the appraisal if errors or deficiencies or explanation was requested the appraiser should do his-her best to cooperate to assure FHA/HUD was getting a good solid appraisal.

Of course there are times when a request is unreasonable or already addressed in the report and if the appraiser has a legitimate reason to decline the request he/she should send the assigned lender an E-mail with an explanation of why it's not required or maybe it's already been addressed in the original report. ** Paper trail showing you are not just a jerk.

If the appraiser wants to play hard-ball
underwriter can forward the appraisal to their FHA/HUD appraisal department with a note pointing out what errors or deficiencies were observed in their review and what attempts were made to get the original appraiser to explain or make the required or necessary corrections. If review at FHA finds issues the appraiser has no defense because FHA/HUD is your main-client , user and insuring the loan.
 
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BRCJR

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My HOC has informed me many times that even on a FHA transfer the new lenders FHA Underwriter is responsible for the review of the appraisal and she has the right to ask the appraiser for corrections or comments. The main client is FHA/HUD for insurance purposes and the original lender released their interest when they transferred the case-number and that lender is no longer in the picture. Your client now is the new lender and FHA/HUD.

When the appraisal has deficiencies or errors FHA/HUD will back the underwriter who requested additional information. Remember FHA & VA are portable appraisals and once transferred the new lender funding the loan and FHA/HUD are the clients.
How can I have a "new" client that I have no relationship with?
 

Eric C

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Jul 25, 2006
Professional Status
Certified Residential Appraiser
State
Florida
My initial guess is that no I can't make changes for the new lender but I want to make sure before I reply to them.. Glenn... so you would make the revisions for the new lender even tho the old client is still on the report?
 

bart nathan

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Jun 9, 2005
Professional Status
Certified Residential Appraiser
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California
I keep this saved when I get those requests.


Dear (Your Name) ,

Thank you for contacting the FHA Resource Center. The information you requested in response to your inquiry is provided below. If the information does not fully address your question, please forward this email (do not reply) to [email protected], and provide additional information so that we may better serve you. You may also speak directly to a customer service representative by calling 1-800-CALL-FHA (1-800-225-5342) or visit our online knowledge base at www.HUD.gov/answers, 24 hours/7 days a week.

Can the new Mortgagee require corrections/inspections from the appraiser on a transferred case?
In cases where a Borrower has switched Mortgagees, the first Mortgagee must, at the Borrower’s request, transfer the appraisal to the second Mortgagee within five business days. The Appraiser is not required to provide the appraisal to the new Mortgagee.

The client name on the appraisal does not need to reflect the new Mortgagee.

If the original Mortgagee has not been reimbursed for the cost of the appraisal, the Mortgagee is not required to transfer the appraisal until it is reimbursed.

The second Mortgagee may not request the Appraiser to re-address the appraisal. If the second Mortgagee finds deficiencies in the appraisal, the Mortgagee must order a new appraisal.

For additional information see Handbook 4000.1 II.A.1.a.iii.(B)(8) at http://portal.HUD.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh
 

CANative

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Jun 18, 2003
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California
Lenders have always been able to use an FHA appraisal that was done for a different lender without having to change the "client" on the report. The report is transferred from the original lender to the new lender and does not involve the appraiser at all to accomplish this process.


The big caveat to the transfer process is that the new lender must use the transferred appraisal report "As is" without modification. In the event the "new" lender wants changes to the original report you are not allowed to make any on their behalf. As noted above by BRCJR the original lender must process and and all change requests as the original client for FHA reports due tot the fact that appraisal FHA reports remain with the property for a period of time (6 mos) and be appropriately documented

For non-FHA assignments, any change requests would require preparation of a new report. In the event this occurs the appraiser would be required to disclose the prior service of the initial report under USPAP however.

Pretty sure it's 4 months now.

The reason the OP can't do what this new lender wants is because appraisers can't disclose confidential information or assignment results to anyone but their client. Their client can do whatever they want with the report.

Why would non-FHA assignments be any different? The appraiser can't prepare a new report with a different client name. That's "re-addressing."

Bottom line there is nothing the OP can or should do here.
 

Terrel L. Shields

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Arkansas
@bart nathan and @CANative nailed it. Don't allow such scope creep not only from the FHA rule book aspect, and the waste of your time, but to educate lenders that they might be endanger their own status with FHA by violating regulations. They should want to know. Nice way to handle it Bart.
 
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