Voice of the Appraiser In-Depth Report

[Tom D]

The 'work around', find another career to make a profit. Do the ones you like part time to pay the bills.

 

[Jayjay25]

Do the GSEs have the right to build their program this way or not? That is the question.

The answer to this question is no. The mandated user of the appraisal, which is required by law due to decades of historic misconduct, should have no right to influence the appraisal process in any way.

There is definitely a conflict of interest here. Fannie/freddie remain in government conservatorship and continue to have their profits siphoned that otherwise would have been used to lobby the government for reduced regulations. I guess they just cut out the middle man. Oh boy, the lobbying organizations must not be happy with this development.

 

[chad hampton]

And all this time I thought LO providing estimates of value was the worst thing any human being could do. Turns out they were just providing those estimates to the wrong group.

What a profession. No leadership. Everyone at the top are crooks.

 

[George Hatch]

In my state, the Appraisal Board has indicated that the appraiser is responsible for everything that is in the report he/she signs. The 'work around'... if you are accepting these assignments.. might be to include an extraordinary assumption.

I don't understand how a state board can decide that an appraiser can be held personally responsible for ANY information that was developed outside of the SOW for their assignment. A property owner lies about occupancy or the rents. A legal description from the public records is incorrect. A roof inspection or a well report.

The appraiser didn't perform the PDR and had no control or input as to any aspect of its development. They have no way of directly knowing anything about it. The reviewer of an appraisal didn't perform the original appraisal. They have no way of directly knowing anything about the property itself. How is the reviewer responsible for the accuracy of the report wherein they didn't see anything that was incorrect and ended up agreeing with the quality of the work and the value conclusion.

How about we make the Board members personally responsible for the accuracy of the information for every report they are working off of?

 

[CGinMN]

Read Cert 10 and ask yourself if it could be interpreted to apply to the data collection report. Don’t tell me what you think it means. Tell me what someone with unchecked authority, such a state board or the GSEs demanding a repurchase, could argue or interpret it to mean.

Here’s what I think: The appraiser is supposed to verify all information that comes from the lender. That includes the PDC.

 

[George Hatch]

The answer to this question is no. The mandated user of the appraisal, which is required by law due to decades of historic misconduct, should have no right to influence the appraisal process in any way.

There is definitely a conflict of interest here. Fannie/freddie remain in government conservatorship and continue to have their profits siphoned that otherwise would have been used to lobby the government for reduced regulations. I guess they just cut out the middle man. Oh boy, the lobbying organizations must not be happy with this development.

As far as the question of what is/isn't an appraisal there has NEVER been a requirement in USPAP that requires personal inspection by the appraiser, so it isn't a minimum requirement of our professional standards. .

The GSEs have a relationship with the Government, but even if you want to pull on that string all that means is that the question then becomes whether or not the govt has the right to control the specifics of their add-on requirements.

(not required under USPAP) = user-driven extras, above and beyond USPAP. Supplemental to the minimums, which in fact the GSE guidelines used to be referred to under the SUPPLEMENTAL STANDARDS RULE which was part of USPAP until the transition to the SOWR made it redundant.

Excluding whatever is prohibited by the law or USPAP, whatever else GSEs have previously giveth they are free to change on the fly. As they see fit. The same as applies to any other users of any other appraisal assignment type. BofA or Wells having their own internal appraisal policy is another example of user-driven requirements - they are free to add/subtract to those extra requirements any time they want.

 

[chad hampton]

The appraisal inspection is part of the appraisal process. Not hard to understand. My state requires the certified appraiser to active and personally supervise anyone providing significant appraisal assistance. And the field appraisal work is an example of that.

The slimy workaround that some of you like to do it all BS. But when they are flown around in suits to speak to appraisal boards, and then threaten appraisal boards when their members start to ask questions, a lot of board members decide this isn't what they signed up for and just decide no regulation or oversight is easier.

Which is what we have now. It's really the wild west when it comes to home valuations.

 

[George Hatch]

Read Cert 10 and ask yourself if it could be interpreted to apply to the data collection report. Don’t tell me what you think it means. Tell me what someone with unchecked authority, such a state board or the GSEs demanding a repurchase, could argue or interpret it to mean.

Here’s what I think: The appraiser is supposed to verify all information that comes from the lender. That includes the PDC.

I think "provided" becomes an arguable point, with previously established precedents as to the GSEs intent and usage of the term. But yeah, if taken in complete isolation to everything else they're saying everywhere else on that form someone can argue that the lender's transmission of the 3rd party PDR could be interpreted as them providing that information to the appraiser.

But as I say, there exist precedents which serve to inform us as to the GSEs actual intent and usage of the term.
To what extent do you personally verify the accuracy of all the information in someone else's appraisal that you're reviewing? Identity of the appraiser redacted, even. And upon which outside report you are developing your own opinions as to the quality of the work and sometimes as to your own opinion of the value of the subject?

Because by use of this interpretation of the #10 term the lender provided that information via transmitting the outside appraisal report to you, too.

If the verbiage in #10 is a sticking point then maybe the GSEs should edit it to clarify (as in, not change) their meaning and intent. That would amount to an anti-lawyer edit that the GSEs never made for C#23 or some of their other previous errors and omissions.

 

[CGinMN]

To what extent do you personally verify the accuracy of all the information in someone else's appraisal that you're reviewing?

Depends on what the engagement letter and preprinted form say.

Below is the certification on the new forms. Why do you suppose the language was modified?

 

[George Hatch]

Well so that's your answer - they have added that edit to their proposed forms revision. The reporting formats which will replace the current forms. Problem solved.

And in doing so they are supporting the appraiser's defense for what the current form currently means to them.