When is a Review Required to meet Std 3?

[Meandering]

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?

I'm with Kona.
If a licensed appraiser, than "reviewing" is appraisal practice,
and Standard 3 applies.

Employment as "staff" does not negate USPAP, nor a state license to opine the value of Real Estate in a particular state.

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[Elliott]

Virtually all USPAP AMC reviews have a very restricted scope of work so the review appraiser can just check off boxes. They can be ten states over. They carefully step over opining because then they'd have to support and they couldn't since they have extremely restricted their scope and they don't know your market. They have to pick on something. My last one made a big deal about highest and best use and it was a farce.

 

[Meandering]

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

Your recourse is to turn them into Florida, and every state they are licensed in, and the cfpb, for opining "value" in the performance of "appraisal practice" in a state where they do not hold a license.

But of course, that'll play into the JT and "centralize everything" gang that want one national license so they can tell you the value of the underlying land anywhere in the country without ever being there.

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[Joyce Potts]

Your recourse is to turn them into Florida, and every state they are licensed in, and the cfpb, for opining "value" in the performance of "appraisal practice" in a state where they do not hold a license.

But of course, that'll play into the JT and "centralize everything" gang that want one national license so they can tell you the value of the underlying land anywhere in the country without ever being there.

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Your recourse is to turn them into Florida, and every state they are licensed in, and the cfpb, for opining "value" in the performance of "appraisal practice" in a state where they do not hold a license.

But of course, that'll play into the JT and "centralize everything" gang that want one national license so they can tell you the value of the underlying land anywhere in the country without ever being there.

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No argument from me. That's assuming I have faith in the FREAB. Guess how the FREAB AMC board members are likely to vote.

 

[Meandering]

No argument from me. That's assuming I have faith in the FREAB. Guess how the FREAB AMC board members are likely to vote.

They can vote anyway they want, and then you turn the entire thing into the ASC who is supposed to be monitoring................

 

[Meandering]

And if you turn it over to the ASC,

you might question the "state supervision" of a board staffed by the people it is supposed to be supervising, who, are, still held to employer/employee responsibilities, without regard to board appointments.

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[Meandering]

An AMC employee, appointed to a board that supervises the employer.

 

[George Hatch]

I get it if the Reviewer is asking for legitmate corrections, blatant ommisions, etc., but when a lic or cert appraiser takes issue with the development of reporting, why is the reviewer not bound by USPAP, George?

This reviewer did not invite discussion, she demanded things be removed on a topic that was germane to my particular market. She's out of South Carolina and not licensed in Florida. She opined to my development and reporting.

Again, why is the Reviewer not bound by USPAP?

The way I read your explanation was that the reviewer sent you the email. You did not indicate nor do I assume that they sent that to the lender. Maybe they did, I don't know.

If that's all they sent to their client then I'd agree that's a problem due to errors and omissions in their reporting. But for all you know they may NOT have done that. They might not even have sent any appraisal review report at all to their client. Or, they might have sent an SR3/SR4 report in either with or without the email content. You are apparently assuming all they sent their client was that email, and your assumption may be correct because there are stupid people out there.

In the abstract, me sending you that email can be argued to be part of my SOW as a reviewer if my assignment includes instructions to contact you and resolve any issues. How else could I meet that element of my development without discussing it with you?

Now as a matter of style I avoid committing to any opinions or conclusions other than what i can point to as a fact. An example would be if I pointed out a math error or an apparent inconsistency, or if I noted the omission of some element of your assignment such as you not providing an "as is" or an insurable value. Those aren't necessarily opinions and such. But even if it is a matter of opinion, if I express an interim opinion to you in such an exchange does that really amount to my assignment results?

I guess I'm asking where you think the dividing line is between me interacting with the appraiser during the course of developing my SOW as a reviewer vs me conveying to my client the results of my assignment?

 

[George Hatch]

I see the state licensing issue and who has jurisdiction over this individual's actions as being separate from the question of what is/isn't an appraisal review report.

 

[Meandering]

I see the state licensing issue and who has jurisdiction over this individual's actions as being separate from the question of what is/isn't an appraisal review report.

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

USPAP.
State laws
Federal laws and regulations

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