Q: Are appraisers required to disclose whether they have been engaged to appraise a given property in the past?
A: The agencies’ appraisal regulations do not specifically require that the financial institution obtain information from appraisers as to whether an appraiser has previously appraised a given property. However, the regulations do require that all appraisals conform to Uniform Standards of Professional Appraisal Practice (USPAP), and USPAP requires that an appraiser disclose any services regarding a given property performed by the appraiser within the three-year period immediately preceding acceptance of an assignment, as an appraiser or in any other capacity.47 The agencies’ appraisal regulations also require a financial institution, when engaging a fee appraiser, to confirm that the appraiser has no direct or indirect interest, financial or otherwise, in the property or the transaction. The financial institution should ask relevant questions of an appraiser to confirm that the appraiser is independent of the transaction and capable of rendering an unbiased opinion.48
47 USPAP, 2018-2019 Edition, Ethics Rule.
48 Valuation Guidelines, section VI.