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Urgent ASB questions

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George W Dodd

Thread Starter
Senior Member
Joined
Jul 9, 2002
Professional Status
Certified Residential Appraiser
State
Virginia
I am preparing the case to go before the VA Appraisal Board.
Attached is a copy of the letter I sent to the ASB asking for clarification in both pdf and word formats. Use it if you like.
I would appreciate anyone willing to support this effort to write the ASB board as well.
The email address to send to is: [email protected] and request a copy sent to each member of the ASB.

Thanks
 

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  • The Appraisal Standards Board copy.pdf
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  • The Appraisal Standards Board.txt
    5.8 KB · Views: 44

Nancy in Friday Harbor

Junior Member
Joined
Jan 16, 2002
Professional Status
Certified Residential Appraiser
State
Washington
You're the BEST!

George,

Great letter! You have directly addressed not only the issue regarding foreknowledge of incomplete/altered delivery, but also pointed out (very neatly, I might add) the inadequacy of the ASB's earlier comments about what a client may do with the report.

I doubt that there are any of us who question how quickly the ASB and state boards would backpedal with a "Well, we certainly didn't mean THAT!!" response if the stuff was to hit the fan on these delivered altered reports. Those who sent reports through AI or Ea or other similar delivery methods, thinking they were secure in the ASB's earlier guidance, would be left slowly twisting in the wind at the end of a state board's rope.

Good job!!

Nancy in gray, rainy, cold, won't it ever be Spring, Friday Harbor
 

Ken B

Elite Member
Joined
Feb 18, 2004
Professional Status
Certified General Appraiser
State
Florida
Very nice letter George.

I hope it is answered clearly and conclusively.
 

Mr Rex

Elite Member
Joined
Jan 12, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
Kenneth, whats the AI's current stance on AIReady delivery of reports?:shrug:
 

Elliott

Elite Member
Joined
Apr 23, 2002
Professional Status
Certified General Appraiser
State
Oregon
Very good letter. Let's hope you've proded them beyond the
'head in sand' response they had in October 2007:

Question:
The September 2007 USPAP Q&A titled “Client Altering the Report,”
included the following statement in its response:

Once an appraisal report is delivered to a client, a client may do a variety of things,
including redacting or removing the appraiser’s signature, or
converting data from the report into a format more functional to the
client, etc.

I am confused by the phrase “a client may do a variety of things…” Is the Appraisal
Standards Board (ASB) suggesting these actions by clients are permissible?

Response:
It is not the ASB’s role to grant permission to clients. The ASB was
acknowledging that clients do a variety of things with completed
appraisals, such as those noted and others; determining whether such actions
are appropriate is not within the purview of the ASB.

The point of the September 2007 USPAP Q&A is that once an appraisal
report has been transmitted to the client, USPAP does not place further responsibility
on the appraiser for the client’s use of the report.
 

Mike Kennedy

Elite Member
Joined
Sep 28, 2003
Professional Status
Certified Residential Appraiser
State
New York
from the Letter:

" 3 Scope of Work Rule (410-411): An Appraiser must not allow assignment conditions to limit the scope of work to such a degree that the assignments results are not credible in the context of the intended use.

a. (419-420) An Appraiser must not allow the intended use of an assignment or a client’s objectives to cause the assignment results to be biased."

George - I suggest SOW Development as stated above has to do with development of value opinion in the report NOT how it is transmitted.

As stated above (extracted from your letter) is not relevant to the AI Ready issue...... or other methods of disembowling an appraisal report.

IMO Scope of Work DOES come into play when an Appraiser must make a decision as to whether KNOWINGLY accepting an order which MANDATORILY requires transmitting an appraisal report VIA third parties which have publicly admitted "magically" transforming an appraisal report into LESS than 100% of its original state is a violation.

The issue IS already addressed in your #2 , 4 and 5 sections.

suggest changing the ending to "thousands of Appraisers".....


other than that.......Excellent ......and thank you.
 
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Couch Potato

Elite Member
Joined
Mar 15, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
I predict a clear and concise answer of, "It's all good. We have no problem with it." The ASB lacks the backbone needed to take a stand on intermediaries and their processes. The reasoning will likely be something based on the lender choosing the process.
 

Fred

Elite Member
Joined
Jan 15, 2002
Professional Status
Retired Appraiser
State
Virgin Islands
In the AI Ready plug in, does the agent have the client's permission to edit the report?
 

George W Dodd

Thread Starter
Senior Member
Joined
Jul 9, 2002
Professional Status
Certified Residential Appraiser
State
Virginia
Are they really the client's agent?
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
Consider this:

I have altered reports that were delivered to the lender and to borrowers that are NOT what the appraiser sent.
Some were converted into an ACI software form, some into AIReady.
Some have minimal alterations - some have major alterations.
Some of the worst alterations I have include: removal of negative comments; removal of photographs; changes in check boxes; comment sections on the forms become "see attached addendum", but somehow they are just no longer included anywhere.
I have X employees statements that they were told to change occupancy, remove negative comments and photos, make it "as is" and remove any "subject to". I have verbals that they were told and taught how to make adjustment changes to justify changing the value, but do not have this one in writing yet.
Reports have been regularly delivered and/or accessible to client personnel in open, non-secured format.
Email between lender and appraiser about 100s of reports delivered by an AMC without the appraiser's signatures that had to be matched up to get signatures on them!!! Seems some, or many???, already have a database of appraisers signatures!!!!!
YOUR DIGITAL SIGNATURE IS BEING PLACED ON REPORTS THAT ARE NO LONGER WHAT YOU SENT!!!!!!!
Appraisers have been removed from approved panels for asking a lender/client for a copy of what an AMC delivered to them!!!!!
Many of the 'connected' AMCs and lenders send appraisals to FNC... the only reason I can think of for this is for the AVMs.

Data - information - is king. Some appraisers are even paying them to steal it!

I'll add more as I go through my collections and memory.
 
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