When is a Review Required to meet Std 3?

[George Hatch]

When you are licensed, and reviewing, that is appraisal practice by a licensed individual.

USPAP.
State laws
Federal laws and regulations

.

I wasn't in disagreement with any of that; but it's still separate from the question of where the reviewers SR3 development process ends vs that communication being considered an SR4 appraisal review report.

Am I supposed to stop communicating with the appraiser when I review their work?

 

[alebrewer]

So, to your point about doing a loan on a 'non-USPAP compliant' report, the minor revisions you mentioned (even the ones where she disagreed with your analysis) don't point to USPAP violations (unless, potentially, the sum of errors were egregious to the point that they affected the credibility of the results - which it doesn't appear they did. As to whether she rendered a S3 review - I'd lean more toward the possibility of rendering an appraisal (S1/S2) insofar as she offered an opinion of site value...

 

[George Hatch]

Yeah, I would never do that in such a discussion. I don't tell appraisers what to think. There's no future in that.

 

[alebrewer]

When you are licensed, and reviewing, that is appraisal practice by a licensed individual.

USPAP.
State laws
Federal laws and regulations

.

It definitely is appraisal practice, but not necessarily appraisal review... depends on the extent of the review. FAQ 335 may offer some guidance on that issue. However, even if it is determined that the service is not a review (e.g. if the 'reviewer' is simply checking for consistency, spelling, etc., if it is appraisal practice, it has to conform to relevant sections of USPAP.

 

[Pittsburgh Pete]

My question remains, did that reviewer step into Std 3 / 4 territory and is she obligated to comply with USPAP. The e-mail that was sent to me comprised her entire review. They were demands based on her non-geo competency of my market as to trends, etc. Good for you, George, and the way you personally conduct yourself when you do 'reviews' or the so-called 'quasi-reviews' that you describe above. But you're NOT answer my basic, fundamental question of Reviewer USPAP compliancy. Where do you draw the line between correspondence, phone calls, emoji's, etc., vs. when a certified appraiser is to comply with Std 3 / 4 USPAP?

Would be obligated to comply with USPAP in the report they submit to their client. But as George has pointed out (twice) the interaction with you is not the appraisal review report.

If your beef were legitimate, the entire review staff at Penndot and their independent reviewers would run afoul of USPAP. However, they ultimately submit a review to their client, Penndot. Their correspondence with me is not the final review report, or a report in any sense.

 

[glenn walker]

I did a residential appraisal on a 1004 of a high-end home in my market of Central Florida before Christmas directly for an out-of-state lender (no AMC) for an SBA loan. A day after submitting the report I get an e-mail from an appraiser who also holds the SRA and AI-RRS designations, out of South Carolina who informs me that she was retained by the lender to do a review of my report and in an effort to bring it up to USPAP and lender compliancy, my report required multiple revisions.

There were two typos, my fault, my bad, no problem. She wanted the signed engagement letter included in my report and verbiage added that is required on all SBA loans. No problem.

The above issues certainly fall under 'housekeeping' or what many refer to as a 'technical' review with, but she went on to note the following:

A- Remove verbiage addressing that many homes in this market that were purchased back during the bubble / bust years have still not recovered some of the higher prices paid. In support, I included the subject's MLS listing and sale history that was a perfect example. She claimed that what happened back eight+ years ago is not relevant and told me to remove it.

B- Disagreed with my Cost Approach of site contributions of $55,000. And yes, I included support for my estimated vacant site value via allocation.

C- Disagreed with my commentary in support of how the adjustments were supported in terms of paired / matched sales and/or sensitivity analysis because I failed to show the specific analysis to support the methods I used.

This review was done in e-mail format with numbered paragraphs, no limiting conditions, certifications or other Std 3 review compliancy.

I know my feelings on this subject, but am looking for a discussion as to what point a 'technical' review steps into a Std 3 catagory and was the reviewer non-USPAP compliant?

Because this reviewer is not in Florida, she and/or the lender can turn me into the State, but where's my recourse?

And lastly, and the most ironic, when I got her supervisor or the chief MAI appraiser for this lender involved, he told me not to bother with the revisions because for the sake of time and expediency, they approved the appraisal and the loan. So in writing, did he indicate they made a loan on a non-USPAP compliant appraisal?

My advice is to move on - They approved your appraisal and no need to rattle the Big Dogs Cage. Sometimes even if you are right there are some hills just not wort dying on. If you file a complaint your Board will require a full copy of your appraisal and your work-file and you just don't want to go there because there are some issues the reviewer brought up that you may not be able to support . The matched pairs on an- upper end or custom home -Are those matched pairs a few of your comparables because I have never had a upper end or custom home where I found true matched pairs ? so is that just a canned comment you use in all of your reports ? As far as sensitivity adjustments that's a legitimate method but impossible to prove. On the Cost approach was it really just backed into ? As far as the comments about the mortgage meltdown or the market back in 2008 , As the reviewer I would not have made an-issue about it but I do agree with her that its old news. Also based on the things she asked about it was not a typical QC or Tech review BUT since she opined no difference in your OMV it probably would be not considered a Standard -3 review and it was really more about the quality of the report. USPAP is always thrown in the mix because if any of the reviewers comments or question are correct then a State Board could find your report deficient, but I tend to think you are free of this mess and the lender is moving on.

Unfortunately we all tend to believe we have Bullet Proof Appraisals- Until Nurse Ratchet from one flew over the Cuckoo's Nest ends up being the reviewer the State gives us to. Also make 100% sure that the SRA or MAI reviewer is also not Licensed in Florida too. Just my opinion but always remember nobody including State Board Reviewers will fall on A Sword for an-appraiser, so I would consider the MAI'S advic to forget it and move on was a free pass because even if the lenders reviewers are not in compliance that does not give your report a free pass if there really are issues with what they found.... Some Hills Just Not Worth Dying on : ) LOL

 

[Meandering]

It definitely is appraisal practice, but not necessarily appraisal review... depends on the extent of the review. FAQ 335 may offer some guidance on that issue. However, even if it is determined that the service is not a review (e.g. if the 'reviewer' is simply checking for consistency, spelling, etc., if it is appraisal practice, it has to conform to relevant sections of USPAP.

Care to comment????????????????

B- Disagreed with my Cost Approach of site contributions of $55,000. And yes, I included support for my estimated vacant site value via allocation.

And FAQs are NOT USPAP

Read page 1 of USPAP.

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[Pittsburgh Pete]

Contacting the appraiser to ask for clarification, explanation, and possible revisions is part of the reviewer's scope of work. Such matters are NOT the appraisal review. Reviewers often raise questions about methodology for the appraiser to consider but again, such questions are not the review.

Seems like premature blather to consider "turning" them in. But then, some can't quite seem to grasp that the communication (Marion?) with the appraiser is not the finished product of the review. Their raising the site value question may be just a way of saying that they feel greater support might be necessary and/or that they don't agree with the conclusion--putting in the appraiser's ear a potential alternative way to address the issue and strengthen the appraisal report.

Some can't seem to take a modicum of criticism--valid or not.

 

[alebrewer]

Care to comment????????????????

Sorry - I thought that was a comment?

 

[alebrewer]

Care to comment????????????????

Also - may want to check into getting a new keyboard - looks like the question mark key gets stuck sometimes.