True Commercial Appraiser Independence
In the last twelve months “appraiser independence” has been codified into various rules and regulations. Appraisers, compliance officers and other industry experts may read the words but fail to recognize the philosophical significance. Appraisers, appraisals, the appraisal function and collateral valuation must be independent (and therefore not dependent on) a loan transaction. A professional appraiser is responsible for providing an independent opinion of value. They should be paid a customary and reasonable fee for the appraisal assignment based upon a clearly communicated scope of work.
How the individual appraiser or appraisal firm manages that assignment is a professional business decision and may fall under state appraisal regulation. How a lender manages its appraisal function is a compliance decision based upon federal and state law. It is contrary to the philosophy of appraiser independence to expect an appraiser or appraisal firm to manage the appraisal function of a lending institution. Yet, this is exactly how many lending institutions manage their commercial appraisal function, despite the catastrophic losses of the last three years. The traditional rotation of a “seasoned” small list of commercial appraisers is rife with incestuous malfunction. Simply put, a handful of appraisers can create a market and perpetrate it into the future. Data is rare and sales are limited. Income, expenses, cap rates, discount rates, absorption rates, vacancy etc. cannot be calculated, forecast, supported or verified through a recorded, open and public source. The “appraiser panel” controls the cost, quality and time-frame.
In contrast, independent management of the commercial appraisal function protects the integrity of the real estate collateral and lending institution. A commercial appraisal management company can build a firewall to promote quality, service and independence. Technologically efficient systems track and manage valuation reports; a diversified group of qualified professionals provide independent and accurate values; and an appraisal management team oversees continual compliance review and oversight.
USAG is committed to promoting the ultimate commercial appraisal management experience. By devoting the necessary resources, correct tools, unparallel technology and expertise; we empower our customers to maximize the efficiency and compliance of their appraisal function.
I look forward to working with each of our commercial client users to design their custom commercial valuation solution.
Sally Carothers, FRICS
Commercial Business Development Manager
200 S. Wacker Drive, Suite 3100
Chicago, Il 60606
Mobile: 614.634.6657
Toll Free: 888.580.604.4122
Fax: 888.604.4122
scarothers@usappraisalgroup.com
http://usappraisalgroup.com/
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