USPAP/firrea Violation

[NUTSaboutAPPRAISING]

Please read the following paragraph and share your thoughts about possible firrea and USPAP violations:
AN ANALYSIS OF THE COMPARABLE PROPERTIES SELECTED IN THE MARKET APPROACH SUGGESTS THAT THE RELEVANT CHARACTERISTICS AND INFLUENCES, INCLUDING ECONOMIC, GOVERNMENTAL AND ENVIRONMENTAL AFFECTING THE SUBJECT PROPERTY OPERATE SIMILARLY ON THE COMPARABLE PROPERTIES AND THE NEIGHBORHOODS IN WHICH THEY ARE LOCATED. THE NEIGHBORHOODS AND COMPARABLES ARE CHARACTERIZED BY SIMILARITY IN LAND USE AND SHARE A COMMONALITY OF VALUES AND INTERESTS.

 

[TEL2002]

Must have been a writer for the Federal government and can not break old habits.

 

[Elliott]

Virtually any USPAP provision allows the state board to disagree with you
on the quality of the comparables selected, though they have no burden
to provide better comparables. "Mr. Appraiser used a comparable
that didn't have the same zoning as the subject and also was different in
design from the subject and is in violation of SR 1-1,2-1, 2-3."
Next case, please.

 

[stefan olafson]

Amen Elliot!

It doesn't really matter what your individual intrepretation is of USPAP, what is important is the schooling and understanding of the reviewer. If you were trained by the ASFMRA then hope that your reviewer took those same classes. Same for the residential side, hope the state hired reviewer has the same concepts and understandings as you do.

Three months apart two appraisers went before the board and the reviewer in each instance cited a lack of information (almost identical) in the income approach for each appraiser. The results of their application for licensure? The first one was granted his license, the second was denied due to violations of USPAP!!!!

NUTS,

It sounds like this appraiser is trying to write a circle around a square peg! If the neighborhoods are similar and are affected by similar influences, then just state it!

 

[Fred]

Please read the following paragraph and share your thoughts about possible firrea and USPAP violations:

What does FIRREA say about comp selection?

As to the statement itself, the first part sounds like the old defintion of "neighborhood," and the latter part says the comps used have similarities. What part of USPAP would such a statement violate?

 

[Mike Kennedy]

Out of context, absent more details, it appears to simply be boilerplate generic filler. No violations evident.

 

[Don Clark]

What does FIRREA say about comp selection?

As to the statement itself, the first part sounds like the old defintion of "neighborhood," and the latter part says the comps used have similarities. What part of USPAP would such a statement violate?

Steven,

That would be my question too. I have never seen a statement in FIRREA about comp selection, and I have copies going all the way back to the original.

 

[Marcia Langley]

I think the OP must have been questioning this part:

COMMONALITY OF VALUES AND INTERESTS.

And thinking about redlining.

IMO the quoted part does not rise to the level of redlining. It seems to be an attempt to say that the appraiser has not gone outside the neighborhood(s) for comps.

However, I think it is an interesting question. What exactly does it mean that the "neighborhood(s)" share values and interests?

Values and interests are shared by people, not properties.

What sort of values and interests are being commented on? Is a neighborhood more or less valuable if the people living there have a comonality of values and interests as opposed to having a variety of values and interests?

Would that same appraiser include a comment that the subject neighborhood has a variety of values and interests, if that were true? It would still be a neighborhood if the uses and properties were similar. One would still select comps from within the neighborhood and the comps would still have similar market forces affecting them.

Regardless of whether one thinks it is a violation of some sort, it does not seem to me like a valid evaluation point for the neighborhood.

===========

Besides that, if one were to analyze/opine the commonality/variety level of every neighborhood's values and interests one appraised in, wouldn't that be a lot of work? And unnecessary liability for how credible that opinion was?

 

[RSW]

I'm still trying to figure out what it means! By the time I get to the second line, my mind starts wondering off to what am I going to have for dinner tonight. I also hate to read an appraisal in all caps too. It hurts my eyes.

 

[Don Clark]

I also hate to read an appraisal in all caps too. It hurts my eyes.

And, at my age and eye sight, small case hurts mine. It is a report, not a love letter. Nothing wrong with all caps in a report. Or do you think that is a FIRREA or USPAP violation too?