Dale
I agree that you can develop your own opinion, but I wanted to discuss the issue of an "administrative review" and the idea of advocacy.
If you are an appraiser, working as an appraiser, regardless of whether under contract or employment. and you have an obligation either by law (regulated by state or feds), consent or agreement with the client, or by a voluntary association with a trade organization, you can not provide an opinion on another appraisers work product outside of the requirements of USPAP Standard Three. You also can not be an advocate, you must be impartial, objective and independent.
Now, a lot of appraisers work, as apparently you do, for banks doing what are refered to as administrative reviews. In my opinion, USPAP would only allow that if your state did not have mandatory licensing, the review was not required under Title 11, and you were not a member of a trade organization that required its member to comply with USPAP. I do not think it is difficult for an administrative review to be made USPAP compliant, usually it means just having the workfile, have a signed and dated certification, and a generic cover letter describing the intended use of the client, and filling in the blanks about the description of the report. I know several folks who with simple changes in their in house forms to become USPAP compliant. I know this seem nitpicky and a bit strident, but I believe this is what USPAP requires.
What we are after as an appraisal profession, is for us to recognize the professional standard, USPAP. When we find ways to opt out, it dilutes the purpose of becoming professionals.
Just my thoughts, this appraisal review issue is a hot button for me. The NCAB believes an appraiser can opt out of USPAP just by coming to an agreement with a client that a review was not intended ot be USPAP compliant. I think this is a bad public policy, imagine if an appraiser could opt out of USPAP on an appraisal for a loan if he and the client agree its ok, regardless of what the law or rules were.
At any rate, thanks for your kind words over the years (yep its been years) regarding my case.
Best regards to a fellow professional
Tom Hildebrandt GAA