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keith

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Reply with quote  #1 
Just got an email from a large nationwide company today stating that the LOE supersedes governing authorities including State Boards, USPAP, Fannie Mae, etc. Really??
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Meatloaf

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Reply with quote  #2 
To some degree, they are right.

They can request an appraisal that doesn't conform to USPAP, FNMA, etc.  I don't know about the state boards though, I still think that if you are acting in the capacity of an appraiser you are obligated to obide by the state regulations.  You could take your appraiser hat off and act anyhow you wanted but that gets iffy real quick.

Which large Nationwide company thinks they can supersede the state?

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MEP

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Reply with quote  #3 
I would argue that any federally related transaction must comply with All Inter agency Guidelines i.e.: FHA, VA, Conv, and USPAP, State Laws, and any court orders. However, the lender/client may add their own supplemental guidelines as long as they do not conflict with the other hierarchy guidelines. Sounds like you have a 'brass tack' trying to be "Top Brass".
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johnmbryant

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Reply with quote  #4 
Nothing supersedes state law.  USPAP is pretty loose with regards to specific actions required by the appraiser.  It must be followed.  FHA, VA, FNMA, etc. requirements, etc. may be ignored unless the loan is being sold or guaranteed by one of these government agencies.  Interagency guidelines are only required in a federally related transaction and pretty much exempt residential appraisals that meet FHA, VA, FNMA, etc. guidelines.

You probably shouldn't use the FNMA 1004 form which has some part of the FNMA guidelines reprinted on pretty much every page.
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Meatloaf

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Reply with quote  #5 
Who is this large nationwide company?
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RubberStamp

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Reply with quote  #6 
I agree with JB.  Man, its still the wild west out there isn't it.  The second I stray from my typical clients I run into anything and everything. 
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