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• Coastal Barrier Resources System (CBRS) area (see Chapter 12, Topic 9 of this Handbook), • Special Flood Hazard Area (SFHA) if flood insurance is not available (see Chapter 12, Topic 8 of this Handbook), • Area subject to regular flooding, whether or not it has been designated an SFHA (see Chapter 12, Topic 8 of this Handbook), • Transmission line easement involving high-pressure gas, liquid
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line easement involving high-pressure gas, liquid petroleum (see Chapter 12, Topic 40 of this Handbook) or high voltage electricity if any part of the residential structure is within the easement (see Chapter 12, Topic 39 of this Handbook), and • Area susceptible to geological or soil instability for new and proposed construction cases unless the builder provides evidence that the site is not
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builder provides evidence that the site is not affected or the instability has been addressed in the engineering design (see Chapter 12, Topic 7 of this Handbook)
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Continued on next page 10-19 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 10.
Properties Not Eligible for an Appraisal Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
Lenders must determine that a property is not eligible for an appraisal at the Determination earliest possible opportunity.
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If an appraisal is requested and the appraiser at Earliest finds that the property is not eligible, the appraiser should stop working on the Opportunity appraisal and immediately notify the lender. b.
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Properties Properties in the following locations are not eligible for an appraisal: Not Eligible for an • Airport Clear Zone (also known as a Runway Protection Zone), if the Appraisal Due property is proposed construction (see Chapter 12, Topic 41 of this to Location Handbook), • Lava Flow Zones 1 and 2 (see Chapter 12, Topic 10 of this Handbook), • Coastal Barrier Resources System (CBRS) area
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• Coastal Barrier Resources System (CBRS) area (see Chapter 12, Topic 9 of this Handbook), • Special Flood Hazard Area (SFHA) if flood insurance is not available (see Chapter 12, Topic 8 of this Handbook), • Area subject to regular flooding, whether or not it has been designated an SFHA (see Chapter 12, Topic 8 of this Handbook), • Transmission line easement involving high-pressure gas, liquid
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line easement involving high-pressure gas, liquid petroleum (see Chapter 12, Topic 40 of this Handbook) or high voltage electricity if any part of the residential structure is within the easement (see Chapter 12, Topic 39 of this Handbook), and • Area susceptible to geological or soil instability for new and proposed construction cases unless the builder provides evidence that the site is not
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builder provides evidence that the site is not affected or the instability has been addressed in the engineering design (see Chapter 12, Topic 7 of this Handbook)
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Continued on next page 10-19 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 10.
Properties Not Eligible for an Appraisal, continued c.
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Property Properties in the following situations are not eligible for an appraisal: Types that are Not Eligible • A property that does not comply with current zoning regulations, for an however, a “legal non-conforming” use is acceptable and should be Appraisal described in the appraisal (see Chapter 12, Topic 12 of this Handbook)
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. • A property that is primarily non-residential is ineligible for VA loan guaranty (see Chapter 12, Topic 11 of this Handbook). • For new and proposed construction cases, if the local building authority routinely performs construction inspections, but none were conducted, the property is ineligible for VA loan guaranty (see Topic 14 of this chapter)
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. • Condo-hotel properties (Condotels) where units are placed in a rental pool and “air” condominiums that do not have a homeowners association are not eligible for an appraisal. (see Chapter 11, Topic 12 of this Handbook
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. (see Chapter 11, Topic 12 of this Handbook.) • A property is ineligible for an appraisal if any party of interest to the transaction, other than the purchaser, is debarred Government-wide, or excluded from participation in the Loan Guaranty program due to a VA-imposed sanction.
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Sanctions typically involve construction complaints or unfair marketing practices.
Lenders must confirm that builders of properties appraised as new or proposed construction have a valid VA-issued builder ID number to ensure that sanctioned builders do not participate in the VA Home Loan Guaranty program (see Topic 11 of this chapter).
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If the sanctioned party is a builder, this restriction applies to any property still owned by the builder, including houses under construction and existing houses.
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VA’s refusal to appraise will not be affected by either the fact that the local building authority approved the work on which the sanction was based, or the builder changes the company’s name or organizational structure or becomes a principal or officer in another organization. 10-20 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 11.
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Builder Identification Numbers Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
ID Numbers VA registers builders and issues identification (ID) numbers.
Builders must Assigned by obtain an ID number for each state where they are building homes for State Veterans who are obtaining VA-guaranteed loans. b.
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Builder For all new and proposed construction properties, with the exceptions of a must have ID new construction property sold by a lender or a home built by the Veteran for Before NOV is his/her own occupancy, the builder must have a valid ID number prior to the Issued NOV being issued. c.
Must Meet The builder must meet any state and/or local licensing requirements.
Licensing Requirements d.
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Licensing Requirements d.
Online List A list of registered VA builders with ID numbers is available at of Registered https://vip.vba.va.gov/portal/VBAH/Home under “Featured Items” in the Builders “Builder Locator.” e.
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How to Builders who wish to apply for an ID number must send the following four Obtain a items to the RLC of jurisdiction: Builder ID Number • Copy of the builder’s license, if required by a state or local authority. • VA Form 26-421, Equal Employment Opportunity Certification. • VA Form 26-8791, VA Affirmative Marketing Certification
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. • Builder Information and Certifications for the VA Home Loan Guaranty program submitted on the builder’s letterhead or attached to a statement on the builder’s letterhead which references it.
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The certification statement and forms are available at: http://www.benefits.va.gov/HOMELOANS/appraiser_cv_builder_info .asp. 10-21 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 12.
Proposed Construction Appraisal from Plans and Specifications Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Construction exhibits must be uploaded by the lender into WebLGY the same Construction day the case number is assigned.
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The exhibits must include: Exhibits • survey or plot plan, • plans sufficient to allow the appraiser to establish market value, • foundation or basement plan, • exterior elevations, • wall section, and • specifications, on either VA Form 26-1852, Description of Materials, HUD Form 92541, or another format that provides essentially the same information in sufficient detail. b.
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The appraiser will certify in the appraisal report, “I hereby certify that the Certification information contained in [specific identification for all construction exhibits, of Exhibits (for example, Smith Construction Plan Type A, 9 sheets, VA Form 26-1852, Description of Materials, plot plan by Jones, Inc.)], was used to arrive at the estimate of reasonable value noted in this report.” c.
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Appraisal The appraiser will prepare the appraisal report subject to the completion per Subject to plans and specifications.
Completion of Construction 10-22 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 13.
Proposed Construction Appraisal from a Model Home Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Notification When ordering the appraisal, the lender must enter the full legal description of to Appraiser the subject property in the legal description block on the appraisal request form in WebLGY followed by “APPRAISAL FROM MODEL HOME.” This will alert the fee appraiser of the procedure to be followed. b.
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Model The model home must be: Home Requirements • fully completed, • the same plan type as the subject home (reversed plans are acceptable), • located in the same market area, and • readily accessible to the assigned fee appraiser. c.
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Contact Contact information for the sales office or an individual who can provide the Information appraiser with access to the interior of the model home must be provided on for Model the appraisal request.
Home Access d.
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Home Access d.
Differences The appraiser must be provided with information concerning any differences between in customer preference items, upgrades, or additional features between the Subject and model home and the subject property.
Model Home e.
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Model Home e.
Statement In the “Comments” section at the bottom of page 1 of Fannie Mae Form 1004, on the Uniform Residential Appraisal Report (URAR), the fee appraiser must insert Appraisal the following statement: “Appraisal from Model Home.
Value has been based on an inspection of a model home of the same plan type as the subject.
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Construction to be completed according to contract dated__________.” Continued on next page 10-23 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 13.
Proposed Construction Appraisal from a Model Home, continued f.
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NOV When issuing the NOV, the SAR must: Requirements • issue the NOV under the guidelines for proposed construction (since the model home was used to illustrate the property instead of plans), and • place the following condition in item 16 of the NOV: “Appraisal from Model Home.
Construction to be completed according to contract dated__________.
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Appraiser is to be contacted for Final Inspection and to provide a statement verifying satisfactory completion.” 10-24 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 14.
Construction Inspections Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Local Many local building authorities have adopted comprehensive residential Building building codes and perform mandatory inspections at the foundation, framing, Inspections and final stages of construction. b.
Confirming On cases involving new or proposed construction, lenders must confirm Local whether or not local inspections are performed.
Inspections Performed c.
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Inspections Performed c.
Purpose of The purpose of the inspections is to ensure that the property: Inspections • is built according to the building codes adopted by the local authority, and • has been satisfactorily completed as evidenced by a final construction inspection or certificate of occupancy. d.
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Missed In the event that the local authority provides construction inspections, but Inspections none were conducted, the property is ineligible to be the security for a VA-guaranteed loan. 10-25 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 15.
Warranty Requirements for New Construction Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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New On a new construction property, the Veteran must be provided with: Construction Warranties • a 1-year warranty on VA Form 26-1859, Warranty of Completion of Construction, or • a 10-year, insurance backed warranty. b.
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Evidence of Evidence that the new construction property was satisfactorily completed will Construction be documented as follows: Completion • If the local authority performs foundation, framing and final inspections, VA will accept the certificate of occupancy as evidence of local authority inspections and satisfactory completion of construction in compliance with local building code requirements
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.
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If the local authority does not issue a certificate of occupancy, copies of the three satisfactory inspection reports or a written statement from the local authority confirming the three inspections were completed and that the construction was found to be satisfactory will be acceptable
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. • If the local authority does not provide construction inspections, the lender must certify that the property is complete (both on-site and off- site improvements), and that it meets VA MPRs for existing construction (see Chapter 12 of this Handbook). 10-26 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 16.
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Warranty Requirements for Proposed Construction Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
On a proposed construction property, the Veteran must be provided with a Construction construction warranty.
Warranty b.
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Warranty Warranty requirements will be determined by whether or not the local Requirements building authority performs construction inspections: • If the local authority performs foundation, framing and final inspections, VA will accept the certificate of occupancy as evidence of local authority inspections and satisfactory completion of construction in compliance with local building code
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in compliance with local building code requirements
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.
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If the local authority does not issue a certificate of occupancy, copies of the three satisfactory inspection reports or a written statement from the local authority confirming the three inspections were completed and that the construction was found to be satisfactory will be acceptable.
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045b1dd1-09d1-41d2-a7db-f00a4582dd1b
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The builder must provide the Veteran with a 1-year warranty on VA Form 26-1859, Warranty of Completion of Construction.
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VA assistance with construction complaints will be limited to defects in equipment, material, and workmanship reported during the required 1-year VA builder’s warranty period
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. • If the local authority does not provide construction inspections, the builder must provide both a 1-year builder’s warranty on VA Form 26- 1859, Warranty of Completion of Construction and a 10-year insurance backed warranty.
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The lender must certify that the property is complete (both on-site and off-site improvements), and that it meets VA MPRs for existing construction (see Chapter 12 of this Handbook).
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VA assistance with construction complaints will be limited to defects in equipment, material, and workmanship reported during the required 1-year VA builder’s warranty period. 10-27 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 17.
Post Construction Inspection by an Appraiser Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Inspection On proposed construction cases, in addition to any local building authority by an inspections, the lender must have the VA-assigned fee appraiser visit the Appraiser property and certify that construction substantially complies with the certified Following construction exhibits upon which the appraisal was based and that the Construction improvements comply with any conditions of the
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improvements comply with any conditions of the sales contract (for example, landscaping, decking, or fencing)
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. b.
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Inspection The report may be prepared on: Report Form • Fannie Mae Form 1004D – Freddie Mac Form 442, Part B (Part A is not acceptable for VA use), or • the appraiser’s letterhead. c.
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Inspection The report must contain: Report Contents • the appraiser’s certification that the completed construction substantially complies with the construction exhibits used in the appraisal, • front and rear exterior photos, and • an invoice for the inspection report. d.
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Incomplete If the appraiser finds that construction is not complete or that there have been Construction deviations from the plans, the appraiser should provide details in the report or Deviations and include an invoice as the appraiser may charge a fee for each inspection. e.
Uploading The appraiser must upload the report into WebLGY. the Report f.
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Contact RLC When a post-construction inspection is needed and the VA-assigned appraiser for Another is not available, the lender should notify the RLC of jurisdiction to have Appraiser if another appraiser assigned.
Needed 10-28 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 18.
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Veteran Building His/Her Own Home Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
Veteran If a Veteran, acting as a general contractor, is building a home for his/her own Building a occupancy, the appraisal must be ordered as “existing” construction.
Home b.
No ID A VA builder ID number and a construction warranty are not required.
Number or Warranty c.
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Number or Warranty c.
Veteran’s The lender must obtain the Veteran’s signed acknowledgement that no Statement construction warranty is provided and that VA will not assist with any construction defects. 10-29 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 19.
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Special Exception for a Veteran Purchasing a New Construction Property Without a Warranty Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Special An exception may be made for a Veteran who wishes to purchase a new home Exception for from a builder who is not more than occasionally involved with VA financing a Property and will not provide either a 1-year VA builder’s warranty or a 10-year Without a insured protection plan.
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In that situation, all of the following will be required: Warranty • The Veteran purchaser’s written acknowledgment that, “I am aware that this property does not qualify for VA assistance with construction complaints, since it was not inspected by VA during construction.
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I am also aware that this new property will not be covered by either a 1-year VA builder’s warranty or a 10-year insured protection plan, as is normally required in this situation
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.” • The builder’s written certification that, “This company is not more than occasionally involved with VA financing and is aware that this property is being accepted without any VA-required warranty on an exception basis, and only upon the request of the Veteran purchaser.
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The dwelling was constructed according to standard building practices and is in conformity with all applicable building codes. • The lender obtains a copy of documentation issued by the local building authority to verify that construction was acceptably completed, such as a final inspection or certificate of occupancy.
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Where local authorities do not perform building inspections, the Veteran and builder must certify in writing that “The dwelling was not inspected during construction by any state, county, or local jurisdiction.” b.
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Builder ID The builder must have a VA-issued builder ID number as the exception only Number applies to the warranty requirement. 10-30 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 20.
New Construction Sold by the Lender Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Appraisal If a lender acquires title to a newly constructed home due to a builder’s Request bankruptcy or cessation of business, the lender must order the appraisal as follows: • As “existing”, not “new”, construction, and • As “IND”, not “LAPP”, as properties sold by the lender are not eligible for processing under LAPP. b.
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The lender must: Documentation Required • provide evidence of property ownership, • complete any repairs needed for the property to meet VA’s MPRs, • obtain a certificate of occupancy from the local authority, and • obtain the Veteran’s signed acknowledgement that “This property is being purchased as existing construction from a lender who acquired this new construction property from the builder.
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There is no warranty and VA will not provide assistance with any construction defects.” 10-31 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 21.
Completed Appraisal Uploaded to WebLGY Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
WebLGY Fee appraisers are required to upload completed appraisal reports into WebLGY. b.
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Access to an VA staff, lenders, agents, servicers, and other authorized requesters with Appraisal VA-issued ID numbers that are associated with the loan number will have access to retrieve the appraisal from WebLGY for review, issuance of the NOV, or other functions. c.
Required The appraiser must contact the RLC for assistance if an appraisal form is not Electronic available in MISMO XML format.
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d625bd59-6719-4a9b-b924-2f34a466de59
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Format d.
Systems In the event that an appraiser completes an appraisal on a LAPP or Servicer Not in Appraisal Processing Program (SAPP) case and WebLGY is not available, the Operation appraiser may email the appraisal to the requester and upload the appraisal as soon as WebLGY is available.
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The appraiser must place a note in WebLGY documenting that this procedure was followed. 10-32 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 22.
Reconsideration of Value Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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Written After the NOV has been issued, the Veteran may request reconsideration of Request value in writing by contacting the RLC of jurisdiction.
If the request is submitted to the RLC through the lender, the SAR is encouraged to research market data and provide a recommendation to the RLC with the Veteran’s request. b.
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Market Providing market data in support of the request, as described in Chapter 10, Data Topic 8, of this Handbook, is encouraged, but not required.
A market data grid is not required. c.
Review by Within 5 business days, VA staff will review the appraisal report, additional VA staff submitted data, as well as the market data available through VA’s AMS.
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VA_Guidelines.txt
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18226b09-547c-411e-8de8-c95bc9fdfea0
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In some cases, VA staff may conduct a field review which will be completed within 20 business days.
If VA staff determines that an increase in value is appropriate, VA will issue an amended NOV. 10-33 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 22.
Reconsideration of Value Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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VA_Guidelines.txt
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03d31b2e-a577-4453-acd8-3b80396637dc
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Written After the NOV has been issued, the Veteran may request reconsideration of Request value in writing by contacting the RLC of jurisdiction.
If the request is submitted to the RLC through the lender, the SAR is encouraged to research market data and provide a recommendation to the RLC with the Veteran’s request. b.
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VA_Guidelines.txt
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407b6ee0-cabd-474d-b82d-e4a5db99901c
|
Market Providing market data in support of the request, as described in Chapter 10, Data Topic 8, of this Handbook, is encouraged, but not required.
A market data grid is not required. c.
Review by Within 5 business days, VA staff will review the appraisal report, additional VA staff submitted data, as well as the market data available through VA’s AMS.
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VA_Guidelines.txt
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e7d6848b-b601-44f2-886f-1a96af720d04
|
In some cases, VA staff may conduct a field review which will be completed within 20 business days.
If VA staff determines that an increase in value is appropriate, VA will issue an amended NOV. 10-33 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 23.
Repair Inspections Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
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VA_Guidelines.txt
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8bd74818-785a-44a4-a82e-9fe0bb6c7c22
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Repair When required on the NOV, repair inspections are completed by appraisers Inspections assigned by VA for: • repairs/alterations/improvements on existing properties, • customer preference items on new construction properties, and • post-construction inspections on properties appraised as proposed construction to confirm that construction was completed in accordance with the certified
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VA_Guidelines.txt
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8325e28d-4aa2-4e75-802d-0519376639c7
|
was completed in accordance with the certified construction exhibits upon which the appraised value was based (see Chapter 10, Topic 17 of this Handbook)
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VA_Guidelines.txt
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976f3ae4-851f-4839-bfd6-bb0e936a2a65
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. b.
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VA_Guidelines.txt
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1b565807-1c08-4876-8456-ca488f0c8f9d
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Lender When issuing NOVs for existing or new construction properties, SARs are Certification encouraged to condition the NOV for a lender certification of repairs, Encouraged especially repairs performed by licensed personnel, instead of an appraiser certification.
Repair certifications which may involve lead-based paint must be completed by the fee appraiser. c.
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VA_Guidelines.txt
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f7573cc0-5bcd-483d-a31a-244301982dc1
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Notification When repairs have been completed and are ready for inspection, lenders must to an notify the appraiser and provide a copy of the NOV as the requirements on the Appraiser NOV may differ from the recommendations listed on the appraisal (see Chapter 13, Topic 3 of this Handbook). d.
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VA_Guidelines.txt
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f2708a2d-9e5a-4700-ace6-528723940822
|
Contact When a repair inspection is needed and the VA-assigned appraiser is not RLC for available, the lender should notify the RLC of jurisdiction to have another Another appraiser assigned.
Appraiser if Needed Continued on next page 10-34 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 23.
Repair Inspections, continued e.
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VA_Guidelines.txt
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aae6f642-fbef-4f7f-ba01-8d95e817955a
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Repair Inspections, continued e.
Inspection Appraisers may place the repair inspection report on: Report Form • Fannie Mae Form 1004D – Freddie Mac Form 442, Part B (Part A is not acceptable for VA use), or • the appraiser’s letterhead. f.
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VA_Guidelines.txt
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2feb5938-ee60-4aa6-9831-b9fdd6437e2c
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Inspection The repair inspection report must: Report Requirements • list the items on the NOV, • certify that quality materials were used, • certify that the items were completed in a satisfactory manner, • identify any non-compliant items, • include photos of all items, • be signed by the appraiser, and • uploaded into WebLGY. 10-35 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 24.
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VA_Guidelines.txt
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cf72344b-a064-45f5-837d-c9a0b9cc33df
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Appraisal and Repair Inspection Fees Change Date March 11, 2019 • This chapter has been revised in its entirety. a.
Based on The maximum appraisal and repair inspection fees allowed by VA are based Fees for on customary fees for similar services in that vicinity.
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VA_Guidelines.txt
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a213f64b-cc19-4dba-a631-c758a555b9e6
|
Regardless of the Similar amount of the maximum fee, appraisers must not charge Veterans more than Services they charge other clients for similar services.
VA will entertain additional fees in unusual circumstances. b.
Fees Listed Appraisal and repair inspection fees can be found at: Online http://www.benefits.va.gov/HOMELOANS/appraiser_fee_schedule.asp. c.
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VA_Guidelines.txt
|
16ff10f8-2085-49fb-8c68-4572c3c11d8f
|
Mileage Mileage may be charged in accordance with the RLC’s fee schedule.
The fee per mile is based upon the GSA mileage rate which can be found at: http://www.gsa.gov. d.
|
VA_Guidelines.txt
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a9e201b4-527c-443a-aace-33d32f8573b1
|
When an appraisal is ordered, the requester must certify in WebLGY that the Certification appraisal fee has been collected and is being held to be paid to the appraiser that the Fee before the appraisal request will be assigned to an appraiser. will be Paid e.
Fee Must be Appraisers are not authorized to collect appraisal fees directly from Veterans.
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VA_Guidelines.txt
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07a1c2d7-e011-4a52-85d7-9afea24fd289
|
Paid by the Fees must be paid by the requester who placed the appraisal request.
Requester f.
No “Rush” VA expects the highest level of service will be consistently provided to Fees Veterans and their mortgage lenders.
No fees for “rush” or “priority” service are acceptable.
Continued on next page 10-36 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 24.
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VA_Guidelines.txt
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aabf4893-a737-4624-a2a5-0fbb7f1b0c8e
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Appraisal and Repair Inspection Fees, continued g.
Appraisal On liquidation appraisals, the servicer may request reimbursement of the Fee Included appraisal fee that was paid to the appraiser when filing the claim under on a Claim guaranty.
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VA_Guidelines.txt
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0c07b9e3-5f6f-4d1c-89ad-fc8e000ba773
|
In the event that the borrower requests to pay the full arrears after the appraisal is performed, the servicer must include the cost of the appraisal in the calculation of the total amount due. h.
Complex VA fee and timeliness schedules cover fees for typical appraisals.
Appraisal Properties assignments that are complex in nature may require additional resources and time.
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VA_Guidelines.txt
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ca0e8c53-d1aa-41df-b0d8-f750ea1896a5
|
If an assignment is determined to be complex in nature, appraisers may negotiate additional fees with the lender, subject to VA approval.
Fee should not exceed what is reasonable and customary for a similar complex property type in the market area. 10-37 VA Pamphlet 26-7, Revised Chapter 10: Appraisal Process 25.
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VA_Guidelines.txt
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