ucbruin
Elite Member
- Joined
- Mar 11, 2014
- Professional Status
- Certified Residential Appraiser
- State
- Massachusetts
Have it your way....Appraisers aren’t part of the lending industry, we are supposed to be independent of the lending industry.
Have it your way....Appraisers aren’t part of the lending industry, we are supposed to be independent of the lending industry.
Don't know what protocols are for other states, but in Texas - if an appraisal is turned in for, let's say... comp selection, the investigator is obliged to investigate the ENTIRE report. So that, if an appraiser develops the CA - even though Cert 4 says they put no weight on it - if it's not well documented, that appraiser could face discipline by the board.I don't care. Problem I have is we are supposed to write the report so the user(s) can understand it. But if a non intended user doesn't understand it they can still turn it in to the state for whatever whim they have.
Lawyers ****** it up for EVERYONE.Don't place blame at the feet of outside forces....
Lawyers **** it up for lawyers....
Used car salesmen **** it up for used car salesmen....
Contractors **** it up for contractors....
You don't know what would have happened without appraisals. I know for a fact that some deals DIDN'T get done as a result of appraisals. I also know some deals DIDN'T get done because of appraisal reviews.Never once in my time as an appraiser have appraisers prevented a housing crash....
Keep dreaming....
In counterpoint, if a state looked at an appraisal and didn't take note of other problems those problems would persist in that appraiser's work. Not to mention the point that just because a layperson didn't notice the true cause of the problem doesn't mean it wasn't there. The state's obligation in that one complaint isn't limited to that one complaint.Don't know what protocols are for other states, but in Texas - if an appraisal is turned in for, let's say... comp selection, the investigator is obliged to investigate the ENTIRE report. So that, if an appraiser develops the CA - even though Cert 4 says they put no weight on it - if it's not well documented, that appraiser could face discipline by the board.
I've long advocated for investigating ONLY that for which the complaint alleges...
In what way do you think anything I'm saying now about C23 is any different than what I said back then? I still think Fannie screwed up with their reimagination of the meaning of intended use/intended user; for which the ASB did criticize them back in the day and told them they were wrong.If all you're going to do is use the "Fannie approved" paragraph you might as well not bother. It's as meaningless and contradictory as the verbiage on the form and the way it's written it does nothing to clarify the scope of work or the intended users/intended uses as required in USPAP.
Fannie clearly intends for a large number of unidentified users to use the appraisal report for a number of unidentified uses. They refuse to identify the users or their uses or how an appraiser can adequately prepare a single workproduct to meet those different and sometimes conflicting uses. Regardless of how many times we point that out they have chosen to stonewall everyone, pretend their intentions are other than as demonstrated in their forms and in general just throw their weight around. As far as I'm concerned Fannie has deliberately chosen to be deceitful and is working solely in their own interests to the exclusion of everyone else, especially the appraisers.
Fannie's verbiage and all of their explanations for that verbiage are in conflict with USPAP and everyone who chooses to "rely upon" the forms and their meaningless paragraph might as well recognize that right up front. You either choose to clarify your scope of work and your intended users/intended uses to comply with USPAP or you don't - there is no half way measure. You might as well just make your choice and be prepared to live with it.
Scope of Work
Does anyone have an explination of Scope of Work in your appraisal reports that is accepted by Fannie Mae? We've thought about copying what the new GPAR report has under Scope of Work, Assumptions and Limiting Conditions, it's a good explination, but not sure if will be accepted by Fannie Mae...appraisersforum.com
you know the forum is easily searchable...flipflopfish
I have come to believe that Fannie's failure to provide an updated appraisal policy is neither an accident nor an oversight. I think they know that once they formally commit these policies to their selling guide that they will have painted themselves into an obviously indefensible position. That position will be disassembled by the first E&O attorney who argues the case in court. All that attorney has to do to research their argument is do a search on this forum and hit the print button - it's all here.In what way do you think anything I'm saying now about C23 is any different than what I said back then? I still think Fannie screwed up with their reimagination of the meaning of intended use/intended user; for which the ASB did criticize them back in the day and told them they were wrong.
I have been telling everyone from the outset to be specific about naming their intended users and intended uses, and that the stock verbiage on the form is meaningless. Where have you been that you think my advice on it has somehow changed?
Oh brother....You don't know what would have happened without appraisals. I know for a fact that some deals DIDN'T get done as a result of appraisals. I also know some deals DIDN'T get done because of appraisal reviews.
I know this for fact with hard money assignments. Hard money lenders have investors, these investors don't want fairy tales.....they want the facts. Based on some of my reports the borrowers were denied the loan. Angry borrower calls me, I call my client, angry calls stop. The truth hurts.You don't know what would have happened without appraisals. I know for a fact that some deals DIDN'T get done as a result of appraisals. I also know some deals DIDN'T get done because of appraisal reviews.
I believed it then, I believe it now. I would argue that case on exactly those merits and I would expect to prevail in court.I have come to believe that Fannie's failure to provide an updated appraisal policy is neither an accident nor an oversight. I think they know that once they formally commit these policies to their selling guide that they will have painted themselves into an obviously indefensible position. That position will be disassembled by the first E&O attorney who argues the case in court. All that attorney has to do to research their argument is do a search on this forum and hit the print button - it's all here.
I think Fannie is playing a waiting game and hoping that the common usage of the forms for a couple years will establish some sort of precedence of reasonableness. It won't, of course, because the conflicts were pointed out before the forms came online and have been routinely and uniformly criticized by everyone since then.
keep telling me about the sow