Appraisal Review & Advisory Opinion 20 Controversy · 2017-06-23 · The perception at a bank’s...

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Appraisal Review & Advisory Opinion 20 Controversy Presenter: Lisa Kimbro, MAI, AI-GRS

Transcript of Appraisal Review & Advisory Opinion 20 Controversy · 2017-06-23 · The perception at a bank’s...

Page 1: Appraisal Review & Advisory Opinion 20 Controversy · 2017-06-23 · The perception at a bank’s credit department is something like this: • The appraisal department engaged an

Appraisal Review & Advisory Opinion 20 Controversy

Presenter: Lisa Kimbro, MAI, AI-GRS

Page 2: Appraisal Review & Advisory Opinion 20 Controversy · 2017-06-23 · The perception at a bank’s credit department is something like this: • The appraisal department engaged an

• Practicing appraisers know USPAP, and appraisers that complete

review work know USPAP’s Standard 3. But what about USPAP’s

Advisory Opinion 20?

• USPAP’s Advisory Opinion 20 addresses an appraisal review

assignment that includes the reviewer’s own opinion of value.

• What is the “controversy” with AO 20? It is the suggested language

that reviewers can use when they are not providing an opinion of value

as part of their review scope of work.

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• Regardless of how reviewers see this … clients may believe thereviewer’s scope of work automatically includes the revieweragreeing (or disagreeing) with the appraiser’s value opinion.

• Reviewers should be aware of this perception, or expectation.

• One of the primary reasons appraisals are reviewed is to obtainconfirmation of the accuracy of the value conclusion –essentially a second opinion of value.

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• Why wouldn’t our clients expect that a reviewer who is qualified todevelop an opinion about the “quality” of another appraiser’s workalso take ownership of the value conclusion as part of the review?

• Clients may not understand that a review assignment thatincludes the reviewer’s concurrence with the appraiser’sopinion of value is actually a two-stage assignment:

1) an appraisal review, and

2) a value opinion by the reviewer

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Why is this a two stage assignment?

If the reviewer states agreement with the appraiser’svalue conclusion, the reviewer has provided anappraisal too.

DEFINITION OF APPRAISAL:

1) The act or process of developing an opinion of value, or

2) An opinion of value

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• AO 20 does not address the idea that clients may have pre-existingideas or expectations about the reviewer’s scope of work.

• The questionable language offered in AO 20 is found on Page 137,“Illustrations of the Language in an Appraisal Review ReportWITHOUT an Opinion of Value” (AO 20 starts on Page 133 of USPAP).

• The intent of the language is to communicate that the revieweris not expressing an opinion of value (including concurrencewith the appraiser’s value).

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Examples of the Questionable Language in AO 20:

• The value opinion stated in the appraisal is adequately supported.

• The value conclusion is appropriate and reasonable given the data and analyses presented.

• I approve the appraisal report for use by (name) Bank.

Might the client take these statements to mean the reviewer agreeswith the appraiser’s value conclusion?

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The language examples in AO 20 are weasel words …

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From Wikipedia:

“A weasel word is an informal term for words and phrases aimed atcreating an impression that a specific or meaningful statement hasbeen made, when instead only a vague or ambiguous claim hasactually been communicated. This can enable the speaker to laterdeny the specific meaning if the statement is challenged.”

Vague or ambiguous language = potentially misleading.

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• Weasel words are contrary to the stated purpose of USPAP …

To promote and maintain a high level of public trustin appraisal practice … by communicating in amanner that is meaningful and not misleading.

• Instead of using weasel words, focus on the client’s expectation or perception of the service being performed.

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The perception at a bank’s credit department is something like this:

• The appraisal department engaged an appraiser on their approvedappraiser list.

• The appraisal department’s qualified reviewer accepted this report (thereview does not indicate the appraisal was rejected and the reviewer hasnot provided a different value conclusion).

• The appraisal report (including the value conclusion) can be relied uponfor the bank’s decision making purpose.

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Why should we be concerned with our client’s expectation or perception

of the service and scope of work we are performing?

The purpose of USPAP is to promote and maintain a highlevel of public trust in appraisal practice … by communicatingin a manner that is meaningful and not misleading.

And the weasel words in AO 20 are contrary to the stated purpose…

But the Advisory Opinions are not part of USPAP ???

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Included in the FOREWARD to the Advisory Opinions is the following:

• Advisory opinions are not part of USPAP.

• Advisory opinions are a form of guidance issued by the ASB toillustrate the applicability of USPAP in specific situations andto offer advice from the ASB for the resolution of appraisalissues and problems.

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So Advisory Opinions are not “part of USPAP”

… and yet they are called USPAP Advisory Opinions

… and they are published in the same volume as USPAP

Perhaps the USPAP Advisory Opinions should be identified as:

“ASB Guidance on Selected Appraisal Issues”

There are currently 31 Advisory Opinions presented on more than 100 pages in the current edition of USPAP.

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Question: Why do clients obtain appraisal reviews?

Reviewers need to know this – understanding the purpose and theintended use of the review are CRITICAL when establishing anappropriate scope of work.

Answer: Reviews are performed to reinforce the client’sconfidence in the credibility of the appraisal work and its

conclusions.

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Appraisal Review & AO 20 Controversy

The appraisal profession is no different from others in that clients oftenseek second opinions from other professionals.

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Intended Uses of Appraisal Reviews

Common intended uses revolve around valuation confirmationand quality control for specific decisions, including:

• Lending purposes including loan origination and portfolio monitoring

• Governmental purposes including taxation and eminent domain

• Litigation purposes involving property valuation disputes

• Business purposes including buy-sell-lease-build, and charitable donation

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If the credibility of the value conclusion is important, obtaining asecond opinion of value from another appraiser (in the form of anappraisal review) makes a lot of sense.

If the client is a federally-regulated lender, how often would it be anacceptable scope of work to complete a Standard 3 review that didnot include the reviewer’s opinion of value?

Keep in mind that virtually all lending decisions involve a loanto value ratio … and LTV is a meaningless ratio without acredible opinion of value!

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Scope of Work Concepts – Appraisal Review

The client’s intended use drives the appraisal review scope of work.

• An acceptable scope of work includes the research and analysesnecessary to develop credible assignment results.

• An acceptable scope of work meets or exceeds the expectations ofparties who are regularly intended users for similar assignments.

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• The appraisal review scope of work can vary considerably, and maychange during the review process.

• There are no pre-printed forms for CRE appraisal reviews, thoughthe use of templates is common. Pre-printed review forms are morecommon in residential lending.

• One residential review form that specifies an extensive scopeof work is the Fannie Mae 2000/Freddie Mac 1032 form. Seehttps://www.fanniemae.com/content/guide_form/2000.pdf

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SCOPE OF WORK (first paragraph, Form 2000)

The scope of work for this appraisal field review is defined by the complexity of theappraisal report under review and the reporting requirements of this report form, includingthe following statement of assumptions and limiting conditions, and certifications. Thereview appraiser must, at a minimum:

(1) read the entire appraisal report under review, (2) perform a visual inspection ofthe exterior areas of the subject property from at least the street, (3) inspect theneighborhood, (4) inspect each of the comparable sales from at least the street, (5)perform data research and analysis to determine the appropriateness and accuracyof the data in the appraisal report, (6) research, verify, and analyze data from reliablepublic and/or private sources, (7) determine the accuracy of the opinion of value, and(8) assume the property condition reported in the appraisal report is accurate unlessthere is evidence to the contrary.

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SCOPE OF WORK (second paragraph, Form 2000)

If the review appraiser determines that the opinion of value in the report under reviewis not accurate, he or she is required to provide an opinion of market value.

The review appraiser is not required to replicate the steps completed by the originalappraiser that the review appraiser believes to be reliable and in compliance with theapplicable real property appraisal development standards of the Uniform Standards ofProfessional Appraisal Practice. Those items in the appraisal report under review areextended to this report by the use of an extraordinary assumption, which is identified inSection II, Question 2.

If the review appraiser determines that the opinion of value is not accurate, he or she mustpresent additional data that has been researched, verified, and analyzed to produce anaccurate opinion of value in accordance with the applicable sections of Standard 1 of theUniform Standards of Professional Appraisal Practice.

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Outstanding scope of work – detailed and written with unambiguouslanguage. No weasel words here!

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Expectations of Federal Regulators

The Federal bank regulatory agencies (FDIC, FRB, and OCC)understand the appraisal and appraisal review process.

The Interagency Appraisal and Evaluation Guidelines(12-2-2010) are still the law of the land.

The Interagency Guidelines include significant discussion aboutreviewer qualifications, the depth of the review process, and stepsrelated to resolving deficiencies in appraisals.

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From the Interagency Guidelines:

“ …Reviewers should possess the requisite education, expertiseand competence to perform the review commensurate with thecomplexity of the transaction, type of real property, and market …”

“ …An institution may rely on the second opinion of marketvalue obtained through an acceptable USPAP-compliantappraisal review to support its credit decision…”

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Supervisory Insights, Winter 2016

The primary article in this issue is “Credit

Risk Trends and Supervisory Expectation

Highlights.”

One of the topics this article addressesis appraisal review programs lackingadequate independence or expertise ofreviewers.

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Appraisal & Review Competency (USPAP)

1. Specific property type (industrial, office, retail, multi-family)

2. Market (local, regional, or national)

3. Geographic area (subject’s location – urban, suburban, rural)

4. Intended use (lending, eminent domain, business decision)

5. Specific laws and regulations (SBA, DOT, IRS, Yellow Book)

6. Analytical method (three approaches to value)

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Appraisal Institute – Leadership in Appraisal Education

The Review Theory courses demonstrate leadership and have beenwell received in the appraisal industry. As of May, 2017 there werealmost 800 members who had been awarded the AI-GRS designationor the AI-RRS designation.

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AO 20 is covered in the Appraisal Institute’s Review Theory courses, including the

questionable language.

In keeping with the stated purpose of USPAP, every effort should be made touse unambiguous language, like the language in the Fannie Mae 2000 form!

Instead of “The value opinion stated in the appraisal is adequately supported” or

one of the other examples of language offered in AO 20…

“The appraisal review scope of work did not include the reviewer’sdevelopment of an opinion of value; as such, the reviewer is neitheragreeing nor disagreeing with the appraiser’s value conclusion.”

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• The client’s intended use drives the appraisal review scope of work.

• Are appraisal reviewers acting to maintain a high level of publictrust when they decide to complete an appraisal reviewassignment without providing their own opinion of value?

• Some of the suggested language in AO 20, relative to an appraisal

review without the reviewer’s opinion of value, is contrary to the stated

intention of USPAP.

• The Appraisal Institute is an industry leader, and its members canprovide reviews with more transparent language than the weaselwords offered in AO 20.

Conclusions

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Lisa Kimbro, MAI, AI-GRS

[email protected]

714-565-5618

Contact

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• The Interagency Appraisal & Evaluation Guidelines, 12-2-2010

• USPAP, 2016-2017 Edition, The Appraisal Foundation

• Review Theory – General, Appraisal Institute

• Fannie Mae Form 2000 / Freddie Mac Form 1032, March 2005

• Supervisory Insights, Winter 2016, FDIC

Reference Resources

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Thank You


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