When is a Review Required to meet Std 3?

[Evincere]

It kind of is relevant because a reviewer can influence an outcome, so if the reviewer is suggesting the site value is incorrect (which implies changing it), they should provide evidence to the appraiser who is going to either apply that change or not (since they are signing the report).
Going to the state with this seems a bit much, but a conversation with the supervisor in charge of this reviewer does not, especially if this is standard practice.

The OP first post wrote / inquired

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

The question is relevant because even though the loan was made (and MAI boss who didn’t perform the actual review says no worries) the reviewer can decide (if OP refuses to comply with reviewers requested changes/opinions) to turn the report over to the state regardless. Which I think seems to be the gist of OPs concerns

 

[alebrewer]

The question is relevant because even though the loan was made (MAI boss says no worries) the reviewer can decide (if OP refuses to comply with reviewers opinions) to turn the report over to the state regardless. Which I think seems to be the gist of OPs concerns

So I saw that statement, but I'm not sure what led her to believe the reviewer would potentially be filing a complaint with the state board? Seemed like the reviewer was disagreeing/asking for clarification, but I didn't see any threats by the reviewer in the OP's post?

 

[Evincere]

So I saw that statement, but I'm not sure what led her to believe the reviewer would potentially be filing a complaint with the state board? Seemed like the reviewer was disagreeing/asking for clarification, but I didn't see any threats by the reviewer in the OP's post?

Is it common practice to notify an Appraiser of a complaint prior to filing? How many Appraisers are provided with a cordial notice in advance that a complaint will be filed.

my understanding is that not until the dreaded letter arrives do they know. The OP went over the reviewers head by calling her boss who was not officially engaged to do the review. The loan can be made for sure but there’s nothing to prevent the reviewer from filing a subsequent complaint. Happens all the time

 

[Michigander]

It sure doesn't sound like any of the concerns on the reviewers part rise to the level of turning the OP into the state. It seems more likely the other way around.

Also reads like the reviewer crossed over the line into opinion, but that is easy to have happen. One thing that is lost in the internet age is the tone of someones voice, or the look on their face when having a conversation. I'd give the benefit of the doubt that it might just be lost in translation and move on. Nothing sounded threatening on the reviewers side and may well have been a misunderstanding that occurs because we have gone away from phone calls and face-to-face conversations.

 

[alebrewer]

my understanding is that not until the dreaded letter arrives do they know. The OP went over the reviewers head by calling her boss who was not officially engaged to do the review. The loan can be made for sure but there’s nothing to prevent the reviewer from filing a complaint. Happens all the time

There's nothing to prevent anyone from filing a complaint at any time. It's been my experience, though, that there's usually advance warning - in the form of significant disagreement, threats, etc. I just didn't see that in the post. Not arguing that it is POSSIBLE that the reviewer MIGHT file a complaint, just that I didn't get that from the post.

 

[Pittsburgh Pete]

How do you know that?

And how do you know what you purport to know.

I do know that we engage in a similar process frequently when we submit reports to Penndot for eminent domain. Received an email just this morning requesting corrections and questioning certain aspects of the appraisal submitted. It's part of the process. Deal with it.

 

[djd09]

the client has many options.

one. accept appraisal.

two. reject appraisal.

three. order a second appraisal.

four. see three.

 

[RCA]

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?

Appraisers are entitled to different opinions. Instead of giving her the right to force you to alter your report, she should simply have been left to write her review with a differing opinion.

In fact, it appears that MAI agreed with that position. Since when can reviewers force the appraiser of the report they are reviewing to change it?

If she reports you to the board, they will most likely pass on it. If they don't, then your insurance rates will go up drastically, assuming you tell your insurance company. And that is a major flaw in the system.

I'm guessing not much will happen. It's another reason to stay away from AMCs and lenders.

 

[alebrewer]

I'm guessing not much will happen. It's another reason to stay away from AMCs and lenders.

Easier for a CG to say than a CR, I'd guess...

 

[J Grant]

Too much paranoia out there.
Reviewers are not in the filing complaint business. They are hired to do a reviwe for their client, and it is up to client what to do, if anything about the appraisal, and possibly about an appraiser- if appropriate, But usually the issues are about the work itself. Though an individual might be the exception I doubt most appraisers doing a review would file a complaint unless they see something so egregious.

Imo reviewers are in more jeopardy in getting a complaint filed against them from an appraiser whose report they reviewed, since an appraiser can take it personally,.