Feb 12, 2019 - 03:56 PM
162. DIFFERING SCOPES OF WORK Question: I recently completed an appraisal that complied with FHA guidelines, including a more detailed physical inspection of the subject property than is normally performed for conventional loans. The borrowers changed their minds and are now opting for a conventional loan. Can I simply remove any references to FHA guidelines and resubmit the appraisal for conventional loan purposes? What if I had named FHA/HUD as an intended user in my original appraisal report, can I remove them as an intended user as well?
Response: USPAP would not preclude you from preparing a new report that removed references to any FHA guidelines. However, if you obtained any information as a result of your inspection of the subject property for FHA purposes, you would have to disclose the results of that inspection, even if it were a more thorough inspection than required for conventional financing. For example, if you noted roof problems because you entered the attic when performing your inspection for FHA, you would be obligated to disclose those same results, even if you wouldn’t typically access an attic when inspecting the subject property for conventional financing.
Because FHA/HUD was named as an intended user in your original report, USPAP requires you to treat the request as a new assignment, since the intended user(s) are an assignment element, and as such, cannot be changed once the assignment is complete.
See Advisory Opinion 26, Readdressing (Transferring) a Report to Another Party, and Advisory Opinion 27, Appraising the Same Property for a New Client, for additional guidance.