A rather recent product requested from appraisers is an Enhanced Field Review. These products are generally requested through AMC's for problem loans. They require a retroactive review based upon the date of the original appraisal which is typical procedure. But then, the appraiser is asked for three additional comparables and MLS and public data for the subject property, the original comparables, and the newly provided comparables. Herein lies the pitfalls. Even if the reviewer is in agreement with the original report, three additional comparables leads to the assumption that there may have been better, but overlooked comparables than those originally utilized. Providing MLS and public data for all comparables and the subject generally violates most MLS Board Rules which allow the information for members only.
Those who have been in the appraisal profession 20 years or more, fully remember that appraiser licensing was a direct result of the S & L meltdown. While licensing and regulation of the appraisal profession is a positive result, poor appraisal practices were far from the major cause of that crisis. Rather, it was the appraisal industry which became the major scapegoat. As a result, the changes and regulations on the banking industry were never enacted which would have prevented the abuses which came back to trouble our economy during recent years. History tends to repeat and the Enhanced Field Review can only be viewed as an attempt to place the blame for the most recent financial disaster of the banking industry once again on the appraisal industry. We have already seen the enactment of the HVCC and a multitude of additional requirements for appraisers to meet in their reports. The only rational explanation for the inclusion of MLS and public data is the assemblage of court cases against appraisers of foreclosed and troubled properties. This pits appraiser against appraiser and the result will be the elimination of the appraisal industry since every appraiser is subject to lawsuits.
Appraisers should refuse Enhanced Review report assignments and put an end to this effort.
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