If you are a current FHA roster appraiser, you are undoubtedly very busy. During the last three years, the number of FHA loans has skyrocketed from 500,000 to approximately 1.5 million, while the number of FHA-approved lenders has increased 350 percent.
Most FHA appraisers are aware of HUD’s e-mail list, which provides notifications of FHA initiatives, including mortgagee letters, seminars, and educational opportunities. But many mortgagee letters do not apply to appraisers. Rather, they are intended for mortgage originators or housing counselors.
This article is intended to highlight several of the most recent mortgagee letters affecting appraisers.
ML 2009-41: Reminds appraisers of FHA appraisal performance standards and FHA sanctions that can be imposed upon appraisers who do not meet the standards. Possible sanctions listed in the letter include administrative, civil, and criminal penalties. This letter is merely a reminder; these sanctions were previously set forth in ML 2000-30.
ML 2009-37: Reminds appraisers of their obligation to determine if properties are located in Special Flood Hazard Areas (SFHA). If a property is located in an SFHA, the appraiser must attach a copy of the flood map panel to the appraisal report. The appraiser must also enter the map number, map panel number, date, and zone designation on the appraisal report.
ML 2009-36: Reiterates that as of October 1, 2009, appraisers who are not state certified residential or general appraisers will be removed from the FHA Roster.
ML 2009-30: States that after January 1, 2010, FHA appraisals will be valid for 120 days. Previously, appraisals on existing properties were considered valid for six months, and appraisals on proposed and under construction properties were valid for 12 months.
ML 2009-29: Addresses situations when a borrower switches from one FHA lender to another after the appraisal has been completed. The second lender may order a second appraisal under specific limited circumstances. The first lender must transfer the case to the second lender, and FHA does not require that the client’s name on the appraisal report be changed to the second lender. Furthermore, the second lender is not permitted to request that the appraiser change the client name on the report, but the second lender may enter into a new assignment with the appraiser.
ML 2009-28: Adopts requirements similar to the Home Valuation Code of Conduct (HVCC) by prohibiting mortgage brokers or commission-based lender staff from selecting appraisers or ordering appraisals. The fee for the actual completion of an FHA appraisal may not include fees for management of the appraisal process; these fees must be separate. An appraiser is permitted (but not required) to record the amount of the fee paid to the appraiser in the appraisal report. Lenders are not permitted to improperly influence an appraiser’s judgment, and are responsible for selecting competent appraisers for each assignment.
These brief summaries should not be considered a substitute for a thorough understanding of these mortgagee letters. Additional information, including an index of downloadable mortgagee letters, can be found on the HUD’s website here.
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