Turning in a Bad Appraiser

[Jeff Horton]

I have put this off too long and I have been working on a complaint on a very bad appraisal I ran across some months ago. I have all my comps, land and house sales data together for show and tell. Matter of fact the lender tried hard to get to me "make it work". Seems the lender turned down the appraisal and refused the accept anything from this appraiser.

My question is would you/do you do an actually review form or just right it a detailed letter including the sales data showing the problem? And why do you do it that way?

This is a clear cut case of either fraud or incompetence. Maybe both!

 

[Tim Hicks (Texas)]

Check with you state appraisal board. You can do a free field review, but they may not appreciate it and may require their own investigators do the job. Texas, has a form that has to be filed and you can add addenda stating your case. Hopefully, your state is more proactive than ours.

 

[Pamela Crowley (Florida)]

Jeff,

If you can wait just a little longer to file that complaint, after I get back and a little settled again, I will send you a couple of samples.

 

[George W Dodd]

Depends on your state board. In Virginia you are just wasting your time with the appraisal board. I have cases of absolute fraud and the response has always been NOTHING!

Not talking about little typos here, but big time stuff like ignoring half a dozen great sales in the subject's neighborhood to go several miles away to cherry pick comps.

Not to mention the numerous errors through out the report: incorrect GLA, incorrect sales date, price, financing, land values, amenities, etc...

I do still send in the worst offenders but I just write a letter and include copies of MLS and property record cards as supporting documentation.

ALSO, be advised that if you send in a compliant the other party will most likely be given a copy of the letter and information, including your name.

 

[Jeff Horton]

Alabama Board appears to be aggressive about handing out fines and stuff. Their reputation was such that no appraiser wanted to go before the board. I don't know if that is still true but some of you may remember what it took for me to get approved just to sit for the test for my license. So I have been very hesitant about turning this in.

The state says they will accept anonymous complaints with proper documentation. Not really clear on what that means but I can lay this one out very clearly. I just hate to turn someone in anonymously. I feel like I am hiding. But I don’t want to deal with the Board again either.

As for proper documentation I can clearly lay that out. Rural property with acreage, the appraiser then uses sales in a Golf Course community, very upscale and very restricted. And sales from another restricted community with lake front homes. Neither are close the subject except in size maybe. Better sales were clearly available. The land value in the cost approach is way off. Again, good sales data was available. Then the adjustments in the sales grid appear to state that the site values of the comp sites were lower than the subject. What a joke!! I have printed out MLS sheets on all these sales and they tell the story clearly.

Thanks for the input. I’m going to turn it in. Just now sure if I want to sign my name though.

 

[George Hatch]

Jeff,

I'm sure some will take issue with this, but here goes....

Filing a complaint with a state board can be construed as similar to "the act or process of developing and communicating an opinion about the quality of another appraiser's work", which of course is the defintion of an Appraisal Review in the USPAP. If you have something to say about another appraiser's work, you should do so in a professional manner and in compliance with the USPAP, particularly SR-3. This protects the original appraiser from frivolous peer complaints and protects you from allegations of unprofessional conduct.

When you are filing a complaint about another appraiser's work, you need to protect yourself at least a little from the possibility of a backlash. The most reliable way to do that is to do a fully compliant SR-3 review, including disclosure of your scope of work. The state may not require it, they may even not like it; but they can't ding you for doing it. This way, if the original appraiser tries to make your complaint out to be non-compliant or anything less than professional they'll get shut down right from the start. I would never complain about another appraiser's work without my complaint being completely researched, verified and documented. To do otherwise is actually unprofessional, if you think about it. Would you want someone complaining about your work if they hadn't gone through some due diligence?

Just my $.02.

George Hatch

 

[Steve Owen]

George, good advice, as usual.

Jeff, I don't know about Alabama, but Missouri allows the filing of an anonymous complaint. They don't care whether it comes from an appraiser or someone else. They seem to be pretty good about investigation and also pretty good at ignoring complaints filed by homeowners who thought their appraisal should have been higher. Unless you want to do a bunch of unpaid work, this might be the way to go.

 

[Restrain]

I've got one on my desk now. The appraisal was given to me by the borrower to "assist" me in developing my value. The home is a turn of the century Victorian with additions. To put it mildly, the appraiser that inspected the home did not discuss the quality of remodeling or the deferred maintenance, then appraised the subject as if completely and competently remodeled, using that type of comp while ignoring better comps. The effect is going to be an over-value of approximately 1/3. I am seriously considering sending this report up. However, the fact that it takes the State of Texas 2 years to review an appraisal and, unless you are just short of an ax murderer, only get a slap on the hand, I almost think it's not worth the effort.

Roger

 

[Residential Appraisal Ser]

Forum: We have had a number of appraisers that have contacted us as they didn't want to be involved or were afraid of repercussions.

As a service to our membership the Guild turns in the apprasier under the name of the Guild. We as that the member give us all the infomation and we give it to our internal board for investigation.
If the appraisal appears to be as puported, we report it to the board for investagation. We also follow up on it for results.
We will not act on little things, but fraud or fabracation of the facts we will take action.

William Sentner
President
American Guild of Appraisers OPEIU AFL-CIO
[email protected]

 

[David C. Johnson]

Real good idea.

dcj