Why field review after closing

[Carnivore]

review Fee's offered by AMC's are crap. For that matter most reviews that require the review appraiser to agree with the original MV are just a cheap way to get a more costly 2nd appraisal.

I was responding to the above from Carnivore's post #91 (Italics above ). Would you agree that no review requires an appraiser to agree with the original MV?

Sometimes the Lender Client wants you to agree or disagree with the OA's Stated MV. If you do agree then you have performed and appraisal and are subject to per my state and appraisal.

Look at this and go to page page four, Example #2 https://ncappraisalboard.org/bulletins/Spring2023.pdf

So the reason I have said what I said before is because I have never received a review assignment from an AMC where they did not require me to agree/concur or disagree with the original Appraisal. See the problem. Cheap 2nd Appraisal without actually ordering an appraisal. It doesn't matter if I concur or not concur and provide a my own appraisal grid with new comps or a mixture of new and OP comps.

 

[J Grant]

Sometimes the Lender Client wants you to agree or disagree with the OA's Stated MV. If you do agree then you have performed and appraisal and are subject to per my state and appraisal.

Look at this and go to page page four, Example #2 https://ncappraisalboard.org/bulletins/Spring2023.pdf

So the reason I have said what I said before is because I have never received a review assignment from an AMC where they did not require me to agree/concur or disagree with the original Appraisal. See the problem. Cheap 2nd Appraisal without actually ordering an appraisal. It doesn't matter if I concur or not concur and provide a my own appraisal grid with new comps or a mixture of new and OP comps.

This is different from what you stated before ( which was some reviews require you to agree with the OA opinion of value )

That is correct; the field review form asks a series of other questions then the last question is, do you agree or disagree with the opinion of value from the appraisal? Either way, agree or disagree, the reviewer has done an appraisal.

It is, in a sense, a second appraisal ( as well as a review ). It should not be cheap, however. Of course, some AMCs pay horrendous cheap fees for reviews or appraisals - disgusting - but that is the affliction of our profession .

 

[sputnam]

review Fee's offered by AMC's are crap. For that matter most reviews that require the review appraiser to agree with the original MV are just a cheap way to get a more costly 2nd appraisal.

I was responding to the above from Carnivore's post #91 (Italics above ). Would you agree that no review requires an appraiser to agree with the original MV?

No, I don't agree. Whether a review requires the reviewer to include their own opinion of value or not is determined by the Scope of Work for the review which, in turn is based on the Client's needs. You are correct that USPAP does not require the reviewer's opinion of value but, if the assignment requires it then, it's required by the review.

 

[sputnam]

Sometimes the Lender Client wants you to agree or disagree with the OA's Stated MV. If you do agree then you have performed and appraisal and are subject to per my state and appraisal.

Look at this and go to page page four, Example #2 https://ncappraisalboard.org/bulletins/Spring2023.pdf

So the reason I have said what I said before is because I have never received a review assignment from an AMC where they did not require me to agree/concur or disagree with the original Appraisal. See the problem. Cheap 2nd Appraisal without actually ordering an appraisal. It doesn't matter if I concur or not concur and provide a my own appraisal grid with new comps or a mixture of new and OP comps.

Not just per your state... per USPAP.

 

[Carnivore]

Sputnam, I knew that ,,,,I should have been more precise. The Link I provided above is interesting because a residential Review assignment might possibly be outside the license level of a Residential Appraiser performing a review of a 1004. See Page six(6) Now accepting the review assignment is one thing, but after receiving a copy of the report under review (a house on forty acres 0 the residential review appraiser may have to withdraw if he lacks competence especially if they require the review appraiser ro agree or disagree with the original appraisers opinion.

Page 6 of the link addresses an review assignment of a house + forty acres.

https://ncappraisalboard.org/bulletins/Spring2023.pdf

Tell me what you think please.

 

[J Grant]

No, I don't agree. Whether a review requires the reviewer to include their own opinion of value or not is determined by the Scope of Work for the review which, in turn is based on the Client's needs. You are correct that USPAP does not require the reviewer's opinion of value but, if the assignment requires it then, it's required by the review.

What I was trying to explain was that even if the reviewer checks "I agree " with the original appraiser's market value opinion, the reviewer has ALSO provided their own opinion of value by doing that!! Ther opinion value is that they agree with the OA opinion of value

An opinion of value can be a benchmark, and that is what it is established by checking "did agree -"

 

[sputnam]

What I was trying to explain was that even if the reviewer checks "I agree " with the original appraiser's market value opinion, the reviewer has ALSO provided their own opinion of value by doing that!! Ther opinion value is that they agree with the OA opinion of value

An opinion of value can be a benchmark, and that is what it is established by checking "did agree -"

Yes. That's right. And if the reviewer does that, the review is also an appraisal and must meet Standards 1, 2, 3, & 4... if it's real property.

 

[J Grant]

Yes. That's right. And if the reviewer does that, the review is also an appraisal and must meet Standards 1, 2, 3, & 4... if it's real property.

Exactly. A standard 2 field review or desk review asks if an appraiser agrees or disagrees with the opinion of value in the OA, whether the review appraiser disagrees or agrees with the opinion o value, either way they have performed an appraisal - if they agree they retain their research in a work file rather than putting additional comps on a grid is the only difference.

I fear some appraiser might take a review assignment for a low bid from an AMC, thinking they will just agree with the value and make an easy $- they've still done an appraisal if they do that and are responsible for their value - as much as the OA was for theirs.

 

[sputnam]

I fear some appraiser might take a review assignment for a low bid from an AMC, thinking they will just agree with the value and make an easy $- they've still done an appraisal if they do that and are responsible for their value - as much as the OA was for theirs.

That happens. I see it sometimes when i review reviews. Typically, I send it back to them with a list of USPAP violations they need to fix.

 

[ReviewGuy]

It is not uncommon for field reviews to be done after closing. FNMA/Freddie have requirements for loans sold to them and post-closing reviews can part of it.


FNMA issued Selling Guide Announcement SEL-2021-04 (Announcement), updating QC collateral risk assessment requirements. Currently, a lender is required to obtain an appraisal field review for 10% of the loans selected for QC review in the random sample, and a desk review is required for the remaining 90% of the sample. The new policy replaces the current appraisal QC requirements with a new collateral risk assessment for all loans selected for a QC review in the random sample. If the lender is unable to complete an adequate assessment or appropriately determine the quality of the origination appraisal, it may order either a desk review or field review from a licensed appraiser. FNMA also introduced a new, optional Post-Closing QC Collateral Risk Assessment Analysis review framework and checklist to assist lenders in performing the required post-closing appraisal review. The updated requirements are effective immediately.

Click to view the Fannie Mae Selling Guide Announcement SEL-20201-04: https://www.tenaco.com/wp-content/u...g-Guide-Announcement-SEL-2021-04-05-05-21.pdf

This is not accurate, the GSEs did away with the field review requirement. SEL-2021 simply states that it is no longer required but is simply a tool for the lender to use within their Post Close QC audit plans.