Appraisal Service Anywhere In The United States
The Desk
Appraisal Review Under The Microscope
By Charlie Elliott, MAI, SRA, ASA
This column is the second
of three that I am writing to bring attention to and extol the virtues of the
three most commonly used appraisal review reports as quality-control tools.
These tools include (1) the electronic appraisal review, (2) the desk review and
(3) the field review. They are listed in the order of the least comprehensive to
the most comprehensive, and this series of columns is designed to assist the
reader in making the proper decision as to which review tool is best for a given
situation.
The desk review is a very
commonly used collateral-assessment, appraisal-review tool. It is used to
critique the appraisal of real property, typically on three different occasions.
The first is the pre-funding review, which typically takes place immediately
prior to the closing of a loan. This is arguably the most critical of the times
at which an appraisal will be reviewed. If the review is properly executed, it
can prevent the making of a loan on property where the appraisal is flawed.
This, by definition, means that the review must be made quickly. This factor
works against quality to a degree. The second occasion is the post-funding,
quality-control sampling review. This is typically done to satisfy bank
regulators, mandating that a sampling of all appraisals be reviewed on all
closed loans. This is done, not to prevent the making of a particular loan, but
to identify a weak risk-management system or to put the spotlight on incompetent
or unscrupulous appraisers. There is usually ample time to perform the review,
so there is little pressure to do a quick or hasty job. The third and last
occasion requiring an appraisal review is that of loss-mitigation or
foreclosure. Admittedly, this is after the horse is out of the barn, but it does
provide the lender with information that is helpful in making decisions in
managing slow paying accounts and/or delinquent accounts. There is also ample
time to perform the review without the pressure of a closing looming over the
head of the review appraiser.
The desk review is
performed by a human, as opposed to the various electronic applications used
today in appraisal review. While it is not always required that the reviewer be
a state-certified appraiser, that is the most common way that the review is
performed. In some cases, regulations require that the desk review be performed
by an appraiser certified in the state where the property is located. Since the
desk review is prepared by a human, one may expect a level of logic and
reasoning, not found in electronic reviews, to be applied. Given the human
element, one may expect a superior product from a desk review over that of the
electronic type.
Desk-review standards vary
in scope. It is important that the lender know how the review is to be
performed. Some of the variables of the desk review include whether sales and
subject property data is confirmed, whether additional sales data is researched
beyond that which is included within the appraisal, whether the reviewer simply
offers a pass-fail grade on the appraisal or whether the reviewer offers a
different opinion-of-value of the subject, in cases where the reviewer disagrees
with the appraisers opinion of value.
When is it appropriate to
use the desk review as an appraisal evaluation tool? This question could be
somewhat open ended like the one about how long a man's legs should be. We have
all heard that a man's legs should be long enough to reach the ground. The
answer, concerning the use of the desk review, may be similar. When the desk
review should be used is unique to the situation. It is the middle ground in the
review-appraisal tool bag, more comprehensive than an electronic review and less
thorough than a field review. Some lenders use it as a second line of defense,
when the electronic review indicates a need for more review of a given
appraisal. While this is probably the most used avenue to the desk review, it is
by no means the only way to come to the conclusion that a desk review should be
performed. Institutions subscribing to a higher level of quality control may
require a desk review on all appraisals prior to the closing of a loan.
Issues, such as cost, also
enter into the mix, concerning if and when an Appraisal Review should be ordered
for a particular transaction. Desk-review cost is moderate, typically between
$100 and $200, perhaps somewhere in the neighborhood of half the cost of an
appraisal.
The desk review is covered
in Uniform Standards of Professional Practice (USPAP). Under USPAP, the reviewer
must, when providing a review without a reviewer’s value opinion, state and/or
identify the client, the users, the purpose of the review, the work under
review, the date of the work under review, the effective date of the opinions
and conclusions, the name of the appraiser performing the appraisal, the
effective date of the appraisal review, all extraordinary assumptions and
hypothetical conditions, how these assumptions and conditions affect the
results, scope of the work, reviewer opinions and conclusions and include a
signed certification.
Yes, as with all review
tools the desk review is not without its shortcomings. These include, in some
cases, a lack of independence and the possibility of reviewer bias, as well as
the absence of a subject property and/or a comparable-sales inspection. These
issues, within themselves, do not mean that a credible desk review cannot be
performed most of the time, however, consideration must given to these
weaknesses in the product when other review tasks are contemplated.
In reflecting upon the
benefits offered by the desk review, one would not want to ignore the importance
that the human element offers. There is little substitute for logic and
reasoning provided by a human over that of an electronic review system. Having
said that, the reviewer typically has not actually inspected the subject and
comparable properties, as would be the case with a more-comprehensive appraisal
review. The desk review is a viable option for lenders requiring a middle ground
analysis of an appraisal.
It should be further noted
that there will be times when the desk review proves to be inadequate. In such
cases, a more-comprehensive appraisal review will be required. There is no
substitute for competent and experienced management overseeing and interpreting
the results of a desk review. Institutions not having qualified in-house support
for this function should consider the possibility of employing experts in this
field or outsourcing this function to a reputable appraisal review firm.
Charlie W. Elliott, Jr.,
MAI, SRA, ASA, is president of Elliott & Company Appraisers, a national real
estate appraisal company. He can be reached at (800) 854-5889,
charlie@elliottco.com or through the company’s Web site at
www.appraisalsanywhere.com. |