Comments on: Inappropriate Form Use

By: Dave

Dave — Thu, 21 Nov 2019 18:54:06 +0000

We appraisers all have our pet peeves. As I always felt as long as the appraisal is not misleading our client and we give a credible analysis, does it really matter what form we use. Mr. Towne , you are correct, why don’t we just use the proper forms. I have AI forms in my software which are very good. But if we just disclose what we are doing, everyone should be on the same page. Ralph has an excellent point. We appraisers have a lot more to worry about than a form. The people who are really in charge are trying to end us.

By: Mike Ford, American Guild of Appraisers (AGA™)

Mike Ford, American Guild of Appraisers (AGA™) — Thu, 21 Nov 2019 14:35:47 +0000

Dave, the only requirement for using the loan form is to state which parts of the preprinted form do not apply-including certifications. Prohibitions against changes BY FNMA do not apply to private parties. You can make any change you want and for those embedded areas supersede them by specific reference.

Admittedly it is easier to just use the GPAR form and not have to be bothered trying to identify every single inapplicable section, but it is not prohibited. You own or lease the software. As long as you are not representing the form to comply with FNMA guidelines or to be used in FNMA transactions you ‘are allowed’. FNMA doesn’t ‘own’ the 1004. (At a minimum it is shared with FHLMC -form 70)

On rare occasions (2?, maybe 3?) I’ve had to use the FNMA form. Once when my alamdode was down (I LIKE their GPAR) and I had to use either ACI or Bradford (can’t recall which) and my templates for FNMA forms required less writing to supersede than to write new GPARs from scratch on my secondary software.

Disclose and supersede as required and there is no court in the country that would or could throw the report out unless that court specifically directed another form or format to be used. I think Ralph is right on this one Dave.

By: Ralph

Ralph — Wed, 20 Nov 2019 22:42:57 +0000

I find the form argument as another example of appraisers making a mountain out of a mole hill. During my 1st basics class almost 20 years ago the instructor, a well respected CG, told us you can do an appraisal on a napkin. While I do private work on the GPAR, when I was a new trainee it was all done on the FNMA 1004. While I don’t do that now I’ve yet to hear of any appraiser being sued for doing private work on a FNMA form.

The problems facing our industry are far greater than what form to use. Like a guy off the street can inspect a home for bifurcation, but lenders in the secondary market will not let a licensed trainee inspect a home! Hello Mcfly!!! That makes ZERO sense!!!!

By: Dave

Dave — Wed, 20 Nov 2019 22:12:48 +0000

Residential appraisers are use to using that form as 90%+ of their work is utilized on that form and is the form we are most comfortable using. I don’t do many appraisals for divorces, etc., but if I did and used the form mentioned, I would note in my engagement letter to the intended user of the report that I was using my appraisal software which is generally intended for my lender work. You are correct though, attorneys can be snakes and will find anything to help their clients cause. I definitely would not use a UAD form report as most people have no idea what Q3 and C3 mean.

By: CJ

CJ — Wed, 20 Nov 2019 17:18:30 +0000

Or use the old 1004 vers 6/93