AMC Reviews of Appraisals
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An appraiser associate was having a discussion with one of the head review appraisers at HUD and the reviewer noticed that the Plat Map in the report did not correspond with the site size reported in the URAR form 1004. The appraiser stated that the public record and the Plat map did not agree with each other and that he chose the figure shown in public records. The reviewer questioned why he would choose the public record? He responded that when the report was reviewed by the AMC that they check the site size reported in the appraisal against the public record and if it does not agree, they require the appraiser to change the report and they cannot (will not) forward the completed report to the lender until it is corrected. The appraiser went on to say that the AMC refuses to send it to the lender and refuses to pay the appraiser unless the change is made. He went on to say since the AMC controls the payment to the appraiser that he has no choice but to go along with their request (demand).
This supports my contention that the AMC needs to forward the completed appraisal along with any review that they may do, to the lender and NOT request or demand that the appraiser make changes to the report. Only the lender’s Underwriter should be able to request changes to the report and the lender should be the one that pays the appraiser.
Everyone seems to ignore the fact that the AMC is not a party to the appraisal report, is not the intended User of the report and doesn’t sign the report. Why are they allowed to pressure the appraiser into making changes to the report for any reason even if there are errors or omissions? They should forward their findings along with the completed appraisal report to the lender. It is the lender’s responsibility to request changes to the report if they find it necessary.
The Appraisal Foundation, USPAP and the Mortgage industry should address this issue and correct it.