USPAP And Transferred FHA Files

[Guy Fakelastname]

Hello,
I hope I am posting in the right place. I work for a lender and I am trying to get an idea about a situation that we just found. We had an FHA appraisal transferred to us from another lender. The case number was transferred and lender released the appraisal to us. The appraisal was done subject to some repairs to make the property HUD compliant. The original appraiser came back and stated that per USPAP guidelines, he cannot complete the 1004D/442 for us as he was contractually obligated for the original lender and would have to treat this as a new order and would need to complete a full new appraisal.

I have combed through the USPAP guidelines and I cannot seem to find anything on this topic other than "Advisory Opinion 26" which states "the appraiser cannot 'readdress' (transfer) the report to another party" in regards to changing a lender's information on the original report. But I cannot find anything about final inspections for FHA appraisals. If this is an actual thing then my company will need to make some major changes to our engagement and guidelines but we would need to obtain the specific verbiage. Does anyone know where I can find this information or have any input on the matter?

Thank you so much in advance!

 

[Michigan CG]

He can do the 1004d, he cannot change the original appraisal.

 

[hastalavista]

He can do the 1004d, he cannot change the original appraisal.

Agreed.

In order for this to be fully USPAP compliant, these two things should happen:
A. You email him/her a copy of the report. Yes, I know he/she did it. But the appraiser cannot share that information with anyone but the original client. If you email the original appraisal back to the appraiser, there is on confidentiality violation.
B. This would be a new assignment. The appraiser must disclose his/her prior service (assuming it occurred within the last 3-years).

If the appraiser still has doubts, you can suggest that s/he call the local HOC to verify.

 

[Tom D]

you can have any FHA appraiser do it if the original one does not.

 

[Guy Fakelastname]

Agreed.

In order for this to be fully USPAP compliant, these two things should happen:
A. You email him/her a copy of the report. Yes, I know he/she did it. But the appraiser cannot share that information with anyone but the original client. If you email the original appraisal back to the appraiser, there is on confidentiality violation.
B. This would be a new assignment. The appraiser must disclose his/her prior service (assuming it occurred within the last 3-years).

If the appraiser still has doubts, you can suggest that s/he call the local HOC to verify.

Thank you for the quick replies. The appraiser stated that he called The Appraisal Foundation to verify and they told him he could NOT do the 1004D. I've never heard that before which is why I posted this thread. I will have them call the local HOC.

 

[Guy Fakelastname]

you can have any FHA appraiser do it if the original one does not.

This is great to know. Thank you!!

 

[Tom D]

Thank you for the quick replies. The appraiser stated that he called The Appraisal Foundation to verify and they told him he could NOT do the 1004D. I've never heard that before which is why I posted this thread. I will have them call the local HOC.

a request to verify 'a completed repair' is not an appraisal. it is a service provided mostly by an appraiser. if it's a simple repair you can find a local FHA appraiser to do it if you pay a decent fee.

 

[BRCJR]

Thank you for the quick replies. The appraiser stated that he called The Appraisal Foundation to verify and they told him he could NOT do the 1004D. I've never heard that before which is why I posted this thread. I will have them call the local HOC.

You might want to take a good look at the Appraisal Report you are using. If the information is correct, as you presented, I would hesitate to use that Appraiser. They are showing some competency issues, again, as presented.

This could simply be done as stated above in post # 3.

 

[RSW]

I hardly believe the appraiser was instructed to not do a final inspection. That is just nuts. The original appraiser can do a final inspection just as has been posted above. The appraiser needs some updating on his USPAP as well as FHA appraisal protocol..

 

[Don Clark]

a request to verify 'a completed repair' is not an appraisal. it is a service provided mostly by an appraiser. if it's a simple repair you can find a local FHA appraiser to do it if you pay a decent fee.

Exactly! And, as much as I hate to do so, I also agree with the BCJR post.

By the way, lenders often request an appraiser do a final due to the appriaser being ill, on vacation, or expired. Whether the assignment is for VA, FHA or a conventional appraisal, the final can be done by a different appraiser since a final is not an appraisal. Full disclosure is required as per USPAP as another poster has already noted.