MAY 29, 2020 – Validations are the little known and little used product that get overlooked in the world of Appraisals and Evaluations. The December 2010 Interagency Appraisals and Evaluations Guidelines (IAEG) document has the following section that addresses Validations:
XIV. Validity of Appraisals and Evaluations
The Agencies allow an institution to use an existing appraisal or evaluation to support a subsequent transaction in certain circumstances. Therefore, an institution should establish criteria for assessing whether an existing appraisal or evaluation continues to reflect the market value of the property (that is, remains valid). Such criteria will vary depending upon the condition of the property and the marketplace, and the nature of the transaction. The documentation in the credit file should provide the facts and analysis to support the institution’s conclusion that the existing appraisal or evaluation may be used in the subsequent transaction. A new appraisal or evaluation is necessary if the originally reported market value has changed due to factors such as:
Passage of time.
Volatility of the local market.
Changes in terms and availability of financing.
Limited or over supply of competing properties.
Improvements to the subject property or competing properties.
Lack of maintenance of the subject or competing properties.
Changes in underlying economic and market assumptions, such as capitalization rates and lease terms.
Changes in zoning, building materials, or technology.
Validations answer one simple question – is the value of the real estate collateral equal to or greater than the value in a prior Appraisal or Evaluation? If so, then that value can be brought up to today. If not, then a new Appraisal or Evaluation is needed.
Validations are useful in level to rising markets. They are not very useful in the current market conditions.
However, not all property types have experienced a value decline this year. In general, industrial properties and national tenant leased properties where the tenant has a bond rating A and above, are still candidates for Validations. Apartments might be depending on the age of the prior Appraisal or Evaluation and the property location.
I have updated the Validation Report that I originally developed in 1994. This report is intended to be used by internal bank employees. It is not for use by fee appraisers, as it does not comply with USPAP. If you are a bank employee and want a copy of my report template, just email me at GeorgeRMann@Aol.Com. I will send it to you for free:)
It took me 25 years to finally get Evaluations to be mainstream. Validations are next. They are under utilized. Albeit, today’s market is not ideal for them. But, we will get back to market conditions where they are useful again. My plan is to design a Restricted Appraisal Report (RAR) specific to the Validations need for fee appraisers to use. But, at this time, this is not needed for the most part.
Again, bank staff please contact me if you want a copy of my template.
Everyone stay safe.