AMC Incompetence in Appraisal Management
21 27 10
ATTN: Executive Leadership
Gentlemen, see attached copy of an Alabama appraisal order placed by your AMC, USRES.
Among our many other efforts on behalf of appraisers and promoting appraisal quality, we periodically communicate directly with lenders that use AMCs. We do this to make sure they are aware of any substandard practices or services that may be offered in their name.
This particular issue is not an isolated instance. Though I redacted their names to prevent retaliation, numerous people located outside the state of Alabama received this order for a so called “Legacy Drive By” appraisal report…whatever the hell that may be.
When your AMC sends blast orders out as far away as California, it’s clear they are not the least bit concerned with competency to perform a specific job order. Apparently timeliness for completion is not a very important issue either. This order has been bouncing around the internet for over a week.
Additionally, the order form itself is too minimal to communicate meaningful and necessary information. Since this is a driveby, some information about the physical characteristics not ordinarily found in public records would be ‘nice’.
Do your agents speak with borrowers before placing appraisal orders? Do they ask questions about property condition; upgrades, owner occupancy, rental information, repairs needed, permits or external influences (positive or negative)? Keep in mind this is a driveby. The appraiser will only see a limited front and possibly angular side view of the property.
Is the interest being appraised a fee interest or leased fee? We note the assignment is purportedly for an FHA loan or related to one, but “other” as a transaction type is neither definitive nor informative. Apparently your agents don’t know, or don’t care what the intended use of the appraisal is.
I am writing you now because it’s possible you may be unaware that the ASC and federal regulators hold the LENDER responsible for assuring that your appraisal management is performed competently and in conformance with FIRREA; USPAP and Dodd Frank as well as any other applicable state and federal laws.
Repetitive ‘blast orders‘ does not achieve any of these. Nor does self certification of competency. That is specifically the AMCs and lender-clients obligation. It is a definitive finding, not a default boilerplate presumption. When sent to appraisers as far away as California, the ‘certification’ of geographic competency is ludicrous.
Frankly it reinforces the contention of many, that both your firm and USRES assign orders based purely on lowest fee found with no regard to appraiser competency to perform the specific appraisal.
This particular order has resulted in your firm becoming a laughingstock in an online appraisal group comprised of thousands of the nation’s leading appraisers. It’s a closed group or I’d share the links with you for your own verification.
The best I can do is promise to post any response you may choose to make on the same site. This particular order may be forwarded ASC and your federal regulatory agency (FHA/HUD) for their information, but wanted to give you an opportunity to respond and address the propriety of this order and it’s conformity with applicable regulations before doing so.
I’m told USRES routinely sends orders to out of state appraisers for orders in areas they don’t work in. Is this indicative of the Home Point Financial “We care” motto?
Please don’t hesitate to call if you have any questions. Let us know if you’d like assistance (no obligation or cost) in developing more meaningful appraisal ordering policies.
Vice President, Special Projects
American Guild of Appraisers
OPEIU, #44, AFL-CIO