USPAP violation to get on "Appraiser List"

[Webbed Feet]

Mr. Martin,

Hmmm, that is comical. Because I think FAQ 40 has a far bigger point and so does the confidentiality section of the Ethics Rule. So be irritated all you want. IF "most" of those appraisers had failed to get their clients permission, all this proves is most of the appraisers applying for your employers approved lists did not mind violating USPAP. So what lender was that you were working for? Are they still in business?

Webbed.

 

[Bill Baughn]

State of Nevada years ago told us that providing samples was a violation of USPAP and that Nevada appraisers were NOT suppose to provide samples...

 

[BRCJR]

My job with my employer requires me to review sample work for our approved appraiser list. It is plain and simple for me, if an appraiser has not redacted the confidential information they DO NOT get approved.

I send a letter of approval or of non-approval. I state why they were not approved and request they call if they disagree with the decison I make. Not one appraiser, that has been denied, has ever called to try and correct the situation. I find that fact an interesting fact.

If, a person in charge of reviewing sample work cannot see that the redacted confidential information really has nothing to do with the quality of the appraisers' work, they should not be making those decisons, IMO.

 

[Couch Potato]

I am beside myself at the request of a local bank to provide information to get on their "Approved Appraiser List". I submitted the typical information including resume, E&O, references, and 3 sample appraisal reports. All legal information for the subject property in the sample reports were deleted, as well as the lender/client.

This is the response from the bank:

"He has submitted samples with no addresses on them. Unfortunately, it is impossible to review his work without the addresses on the appraisals. I will hold this information for a short period of time to allow him to provide samples with addresses.

Sorry it took so long to review this. Let me know if you have any questions.

"Ms. Leftfield"
Vice President Mortgage/Loan Operations


My response to the bank:

"The samples provided are typical of what we send to lending institutions. The addresses and any legal information in regards to the subject property are never provided, due to it being against the confidentially law to do so. We have never had a lender to request the actual address of any sample provided."

Today's response from the bank:

"I appreciate the appraiser’s point; However, we must have the addresses on independent appraisals to review this appraiser.
We are actually planning to modify our position and limit the number of new appraisers we are adding”


AM I MISSING SOMETHING??? I CAN'T WAIT TO SEE THE FORUM'S POINT OF VIEW!!!

I don't know about your particular area, but in every place I have every lived property addresses are public information and not remotely confidential. In fact they are plainly posted on the front, curb and/or mailbox.

If instead of a sample, they were paying for the appraisal would you not include the address of the property on their report because it was confidential information between you and your prior client? A request for a sample is an appraisal order; treat it as such.

 

[John "Corky" Harry]

Good thread. Good call Bill Caudell.

 

[Mike Boyd]

It has been many years since I was asked for work samples. Probably before GLB. But, isn't there something that allows regulators, a jury of peers (review appraisers) or the courts to use unredacted reports for review purposes?

Maybe the easiest thing to do is change the address, APN and owner to that of a ficticious property. Who's gonna know? Who's gonna care?

 

[Ray Miller]

My job with my employer requires me to review sample work for our approved appraiser list. It is plain and simple for me, if an appraiser has not redacted the confidential information they DO NOT get approved.

I send a letter of approval or of non-approval. I state why they were not approved and request they call if they disagree with the decison I make. Not one appraiser, that has been denied, has ever called to try and correct the situation. I find that fact an interesting fact.

If, a person in charge of reviewing sample work cannot see that the redacted confidential information really has nothing to do with the quality of the appraisers' work, they should not be making those decisons, IMO.

Now it plain to understand that they did not understand USPAP. Did you send there names into the state? After all what else did they do wrong or doing wrong to this day?

 

[Pat Butler]

I've always thought the best way to do it was to change the subject properties address. That way, none of the property data can be traced back to the subject and the methodology in the appraisal can still be analyzed.

Nothing trumps GLB here, and any appraiser who provides this private info to a third-party is in violation of GLB. Couldn't be any simpler.

 

[Couch Potato]

Just exactly what would make an address "non-public" information and subject to GLB?

 

[Vernon Martin]

I don't know of any rule that requires that the property address be kept confidential. After all, assessor's offices publicize their opinion of value with each address. I've never heard of any litigation of this sort. Of course, those of you want to take the concept of confidentiality to absurd lengths are free to do so, POing any potential new customers, thus freeing you to contribute 1000 posts per year to this forum.