Darn! There’s That Pesky USPAP again! – Here’s what the ASB’s January 2006 Q&A has to say about appraisers that have been engaged directly by the homeowner: http://tinyurl.com/28ls7z
Question: I was contacted by homeowners who want me to perform an appraisal of their home to be used for a loan at a federally regulated financial institution. What are my responsibilities in this potential assignment?
Response: It is an appraiser’s responsibility to disclose to the homeowners that a lender or its agent is required by Title XI of FIRREA to directly engage the services of an appraiser in a federally related transaction. If the homeowners still want to engage you, your disclosure allows you to accept the assignment.
Additional information can be found in Advisory Opinion 25, Clarification of the Client in a Federally Related Transaction http://tinyurl.com/2xbd4m and the October 2006 Q&A on Intended Users & Intended Use.
See my blog post on this topic: http://tinyurl.com/ywyhu3
Brian J. Davis
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