CHASEing USPAP
Chase has turned a lot of appraisers into state appraisal boards. They’ve been responsible for nearly 20% of the Illinois caseload since 2008.
The volume ebbs and flows from one quarter to the next. Not all of their complaints are good. Then again, not all of them are bad, either.
All of their complaints insist that the original appraisal was too high. In their complaint submissions to us, they generally include a letter to the original appraiser that predates the complaint by months.
In Chase’s complaints to us they typically include an appraisal review of some type.
The standard review is a form 2000 as completed by an Illinois appraiser. Sometimes those reviews are helpful. But, not always.
Recently Chase included a Corelogic desk review from an appraiser in Georgia.
First, this Georgia appraiser was not licensed in Illinois to render an opinion of value on a property in Illinois.
Next, and more importantly, this appraiser placed a disclaimer into her scope of work as to her lack of geographic competency for the assignment.
Say what?
Her scope of work stated the following:
“The reviewer does not claim or imply anywhere within the reconciliation report to have geographical competency of the subject’s market area.”
Are you kidding me?
COMPETENCY RULE
An appraiser must: (1) be competent to perform the assignment; (2) acquire the necessary competency to perform the assignment; or (3) decline or withdraw from the assignment.
It isn’t a suggestion, a by-the-way, or a best practice swell idea. It’s a rule.
You cannot disclaim, caveat, discount, or water down the Competency Rule.
Sorry. It doesn’t work that way.
We have already addressed geographic competency in previous issues of this newsletter. There is no such term.
An appraiser is either competent for an assignment or they are not.
USPAP permits practitioners to become competent, which is something Fannie Mae doesn’t seem to care about, either.
If you aren’t competent and can’t become competent; you need to decline the assignment or withdraw.
Its pretty clear, wouldn’t you agree?
Illinois Appraiser Newsletters – October 2011 Volume
- Hybrid Assignments, the Consequences - February 7, 2019
- Bankers Concerned About Appraisals - October 18, 2017
- Third Party Blues - July 19, 2017
