Category: Uniform Standards of Professional Appraisal Practice

COD at The Door? - Can Appraisers Collect at the Door? 28

COD at The Door?

Can Appraisers Collect at the Door (COD)? In the past, it was common for appraisers to collect their fees directly from the borrower at the time of the property visit (i.e., at the door). I would take credit cards, checks, or cash while at the door. Many years ago, this was common. Now, however, that rarely happens and we usually have to wait 30- to 60-days for payment from the AMC client. So recently, when I got a COD order from HUD, I was really surprised. In fact, I thought something was bogus. I needed to check this out since...

Another Draft to a USPAP Draft! Everyone Should be on Their Toes... 13

Another Draft to a USPAP Draft!

Well, don’t toss your reading bifocals in the wastebasket just yet. Apparently, there were so many negative issues with the THIRD exposure draft to the 2020-21 version of USPAP, that the ASB jettisoned it, and will move forward with a FOURTH draft. Everyone should be on their toes, ready to peruse this stellar document when it is released not long from now! Can’t we, please, establish a set of reliable and understandable procedures, and leave them in place for 5 years minimum? Please! Here’s the announcement issued on February 8, 2019, after the ASB meeting in Scottsdale, AZ: (From the Appraisal Foundation)...

Hybrids' Indicated Value & USPAP Coup de Grace, Better off at McDonalds 29

I’d Be Better off at McDonalds

…they provide no documentation as to how their algorithm produces this indicated value… I had to “jump in the pool” and see what these bifurcated appraisals are all about. The names have been withheld to protect the guilty. I recently completed a “bifurcated” report for one of the AMC’s providing this type of service. The form is to be completed on their site and they recently upgraded to the “new and improved” report on their portal as of January 1, 2019. The subject is sited in an urban location and while not an anomaly per se, does display features such...

Third Party Inspectors, Hybrids... Spelling Out the Consequences 9

Hybrid Assignments, the Consequences

The concept of a third party providing one or more functions in an appraisal assignment is nothing new. Back in the 1970s and 1980s there were plenty of appraisers who used somebody else to do the sketch or to take the pictures or to pull comps. The “appraiser” put all of the pieces together and signed the report. Then came USPAP in 1989. Licensing followed shortly thereafter. Today, there are a number of lenders and AMCs who believe that they’ve invented something no one else has ever considered. The bifurcated or hybrid appraisal process. To be clear, we’re not talking...

What's Happening With the New Forms? 11

What’s Happening With the New Forms?

Many of you are aware that the GSE’s are in the process of evaluating the entire appraisal process, including the existing ‘forms.’ This initiative was announced in 2nd Qtr 2018, and reps from both FNMA and FrMac made presentations at various appraiser conferences and other places through the year to gather info and suggestions from all appraisal forms users. This new initiative was never intended to be an immediate make-over; instead, the GSE’s said it was to be an approximate 3 year process. In December 2018, the GSE’s released their Executive Summary (see PDF below) describing what’s been accomplished so...

What If the Algorithms Are Wrong? Weapons of Math Destruction... 12

What If the Algorithms Are Wrong?

Algorithms are everywhere… “Algorithms decide who gets a loan, who gets a job interview, who gets insurance and much more — but they don’t automatically make things fair. Mathematician and data scientist Cathy O’Neil coined a term for algorithms that are secret, important and harmful: “weapons of math destruction.” Learn more about the hidden agendas behind the formulas.” “Algorithms are opinions embedded in code. It’s really different from what you think most people think of algorithms. They think algorithms are objective and true and scientific. That’s a marketing trick. It’s also a marketing trick to intimidate you with algorithms, to...

Is SmartExchange a Problem & Resulting in USPAP Non-Compliance? 27

Is SmartExchange Not USPAP-Compliant?

Is Smartexchange Resulting in USPAP Non-Compliance? This blog is likely going to stir up controversy. It is likely going to have a few folks calling me a loyalist to a la mode, or other similar things. Am I a loyalist? I do not see myself as such, but a la mode has been the only software that I have used in my career for residential form reporting. I do use ACI in the corporate setting as a reviewer and manager in my firm. I like and consider many of the staff at a la mode to be my friends, and I have had long relationships...

Should We Raise the Appraisal Deminimus Threshold to $2 Million? 7

Should We Raise the Deminimus to $2 Million?

Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF.  USPAP compliance is required for federally related transactions. USPAP comprises two parts:...

Increased Regulatory Persecution of Real Estate Appraisers - USPAP 21

Increased Regulatory Persecution of Appraisers

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...

USPAP Confidentiality Questions... Can Using a Contractor Be a Violation? 7

USPAP & Questions on Confidentiality

How can using such a contractor not be a violation? In the context of a real estate appraisal, especially a residential real estate appraisal for a lender thru an AMC, what is confidential? First, look at USPAP’s definition of confidential information (lines 105 – 108 in the 2018-2019 edition). It says “confidential information [is] information that is either…identified by the client as confidential when providing it to an appraiser and that is not available from any other source; or…classified as confidential or private by applicable law or regulation” (ibid; emphasis added). Notice confidentiality flows to the client, not to any...

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