by Steve Owen on Mon Feb 04, 2008 11:39 am
All of those things that have been argued by the multiple sides in this issue have some merit. As Dennis pointed out, some of us may appear to even be arguing more than one facet of this complicated issue... and I don't think that Edd is the only one.
The bottom line, however, or one of the bottom lines, at least, is that an appraiser often appears to be in sour grapes mode when another appraiser is turned in to the Board. This, added to the fact that there may be genuine disagreement about how a thing should be done leads to a bias on my part that appraisers generally should not be the ones doing the enforcement policing.
An example: recently I was given a report on some rather unusual apartment units. I am appraising a similar, rather unusual building, and the owner gave me an appraisal recently done on a similar building. When I read through the report something jumped out at me. The summary report did not give any specific information about the comparable rentals used... it simply stated that a survey of similar rentals leads to the conclusion that the subject units will be rented at market rate. Similarly, the cap rate was discussed in terms of using multiple disciplines, market, band of investment, etc., but did not spell out any of the specific information. There is no way, in reading the report to know if the appraiser really had good information or just made the rates up. This is an apparent failing, but if the appraiser does have good information in file, is not a critical one. Additionally, because the appraisal was done for one of the national, faster-cheaper banks, which I also bid and work for, I am aware of the possibility that it could simply be a scope of work issue... this bank regularly asks for restricted reports even after being told that they will not suit the purpose and having that explained to them.
So, if I were another appraiser, and not myself, it would be easy to turn this report into the Board, describing its apparent deficiencies. What would that accomplish? It would make me look like I was trying to kill the competition, the appraiser would most likely have an explanation that would be satisfactory to the Board, and both of us would have to do a fair amount of unpaid work.
Instead, the better solution is to let the market solve the problem. This particular bank is unlikely to turn this sort of failing in. But, word gets around. If this appraiser does similarly shallow reporting, then other clients, when reviewing his work against that of his competitors, is likely to choose the later.
I'll stick to my original position. Appraisers should turn in obviously fraudulent appraisal work... to the FBI. Appraisers should not, as a general rule, turn work into a Board that they have not reviewed... to do so, might be a violation of USPAP, since it implies that you have formed an opinion of another appraiser's work, but have not met the criteria of Standard 3. Reviewers should turn in shoddy work to the Board, only if there are clear USPAP violations... not if there are simply differences of opinion. And, clients should be the primary complainers to the appraisal Boards when they believe that an appraiser has erred.
Did you ever feel like the world is a tuxedo and you're a pair of brown shoes? - George Gobel