By Barry Bates
The appraisal client is always the intended user.
A lovely concept out in the ether somewhere, but hardly ever the case in practice. The client (who engages the appraiser) is a lending technician or AMC drone; the intended user is an underwriter, servicer or portfolio manager. (This assumes the fact that only about 10% of appraisals are ever done for anybody other than a mortgage
Pretending that they’re the same person (based on the legal concept of a corporation as a person, which facilitates all kinds of evil) allows the left hand, which is handing out cash, to avoid confronting the fact that the right hand is removing money from the borrower’s savings account.
USPAP is intentionally not specific
Finally, the old TAF argument in support of USPAP that its lack of specificity
is only the result of trying to avoid “micro-management” of the appraisal process is just what we former Army wiretappers used to call “cover noise”. It screens from hearing the fact that as it stands, USPAP can be used either to exonerate or
execute an appraiser on political motives regardless of the issue at hand. That’s
why more procedural detail is needed, not less.
Appraiser Judy fails the geocompetence test when she gets a citation from
her state for not having a subscription to local MLS. Yet when appraiser Willie
walks when he fails to check online sources or MLS after the property owner assures him the property is not publicly listed for sale. This same thread of delusion seems to run throughout USPAP, undoubtedly promulgated by crusty old MAIs. If any carbon-based life form tells you something, it’s okay to believe it’s true without any further investigation. Just throw in an extraordinary assumption, even though it’s invalid because it’s impossible or unreasonable.
Another reason for more specificity is the utter failure of the HVCC /Dodd-Frank AMC experiment. Instead of being coerced by a mortgage broker,
today’s appraiser is systematically coerced by onerous documentation
requirements, intimidating email, multiple requests for reconsideration and
arbitrary blacklisting. Appraisal quality is depressed by AMC expropriation of what
was once 50% of a normal appraisal fee. Moreover, residential fees in general
haven’t changed for 20 years.
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