Coester VMS

[To assist us in bringing this matter to a close, you must give us a reason why you are rejecting the response. If no reason is received your complaint will be closed Administratively Resolved]
 Complaint: [redacted]
I am rejecting this response because:
Brian's statement is false, The appraiser indicates that most of
the land is vacant, and on separate parcels and the overall 20+- acres is
larger than typical for the market. He has decided that only the improved
parcel has contributory value and the remaining 19+- acres is excess land. 
Mind you that this is one continuous property with the Home, it does have 3 different tax id's.
This was a refinance and The appraiser did not give the value of what is being mortgaged. The deed is what is currently being mortgaged. 
Regards,
[redacted]

November 18, 2015
Dear [redacted],This is CoesterVMS' second and final response to the above-referenced consumer complaint. As communicated before, with respect to the appraisal of [redacted]'s property, the assignment from the tender was to provide an appraisal on [redacted]. There were no special instructions in the assignment from the lender regarding whether to value one, two, or three lots, or any combination of the three. Furthermore, a deed, title, or survey was not provided to the appraiser prior to the effective date. However-and this is the critical point--even if there were a specific direction from the lender, the ultimate judgment call with respect to the scope of the appraisal is always up to the independent appraiser. Neither the borrower, nor the ender, nor the AMC (CoesterVMS) can define the scope because this would violate the federal requirement that the appraiser develop the appraisal independent of any influence. In this case, the appraiser followed FHA/HUD protocol in treating the unimproved lots as excess land. All of this was explained on page 7 of the addendum. In the appraiser's expert and independent opinion, the 19+-acres were considered excess land as federally defined under FHA/HUD,
CoesterVMS would like to reiterate and underscore that it is not the job of CoesterVMS, as an AMC, to defend the independent appraiser's choice to call the 19+- acres excess land, instead, it is our responsibility to the Lender to make sure that if the independent appraiser deemed two of the three lots to be excess land, that the appraiser treated them in compliance with FHA/HUD guidelines, used best practices to write the report, provided credible results which were clear to the client (the Lender), followed lender/investor guidelines, and was USPAP compliant. In this specific case, this report was reviewed by CoesterVMS and found to be compliant with all of the foregoing requirements.
Sincerely,Tobi A.
In-house Counsel