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Voice of the Appraiser In-Depth Report

That 2-part test for the SOW decision has appeared in every edition of USPAP since the transition to the SOWR. And that test still refers to what the users expect + peers would do when performing the similar assignment.

The SOWR does not refer to any other test for the reasonableness of the SOW decision. If a SOW is not in conflict with the basics and it otherwise meets both elements of that 2-part test then whatever other goalpost you are attempting to insert doesn't exist.
 
I wouldn't say problem solved, but it is an improvement. It is still vague, but it gives the appraiser the opportunity to document verification efforts and limitations, while still providing the GSEs the deniable plausibility they need to scapegoat the appraiser in a repurchase situation.
 
Our experience with the 2055 and reviews and C#23 and such contradicts the assumption that the GSEs intend to scapegoat the appraisers for using the GSE forms under the the GSE policies. But it remains as true as ever that the GSEs are not an appraisal entity and they build their forms for their own usage; not to advocate for the interests of the appraisers.
 
Don't forget Cert #10. Is a PDR from the lender considered a disinterested source? I don't think so.
Why wouldn't the PDR collector be a disinterested source?
 
Because they were engaged or employed by the lender or their agent. Same as the appraiser.
 
But as the appraiser you are required to use that bad information.
I've never read a reg that states the appraisers are required to use information they know to be incorrect. Citation, please?
 
Because they were engaged or employed by the lender or their agent. Same as the appraiser.
Ok, so both the appraiser and PDR collector are interested parties then? Meaning they have an interest in the transaction?
 
Ok, so both the appraiser and PDR collector are interested parties then? Meaning they have an interest in the transaction?
As I read it, the complaint is that the verbiage in the forms are still being worded to the advantage of the GSEs at the potential expense of the appraisers.
 
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