Blacklisting Lawsuit Continues

Isaac Peck

Isaac Peck

Editor & Marketing Coordinator at Working RE Magazine
Marketing Coordinator at OREP.org, a leading provider of E&O Insurance for appraisers, inspectors, and other real estate professionals in 49 states. He received his Bachelors in Business Management at San Diego State University. He can be contacted at (888) 347-5273.
Isaac Peck

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Blacklisting of appraisers by lenders and AMCs
In early 2014, North Carolina appraiser Michael J. McSwain filed a lawsuit against Yadkin Valley Bank and the appraisal management company (AMC) StreetLinks Lender Solutions, alleging that he was retaliated against for failing to reach targeted values. (See Smoking Gun Allows Appraiser to Sue Over Blacklisting)

According to the suit, McSwain performed two appraisals for StreetLinks in late 2012, on behalf of Yadkin Valley Bank, both of which failed to “meet value.” The suit cites explicit emails from the branch manager at Yadkin which state:

“StreetLinks has sent out a BUTCHER on two of my last refis [sic] … make sure he is not sent out in our county and make sure he is not on the approval list…I thought I would let him do these two just to see. NOW THE DEALS ARE DEAD.”

Yadkin then demanded that StreetLinks remove McSwain from the bank’s Approved Appraiser List and according to new discovery documents that have been made public, McSwain was placed on Yadkin’s Exclusionary List in early 2013. McSwain then filed a lawsuit in February 2014 alleging that both Yadkin and StreetLinks engaged in unfair and deceptive business practices and were engaged in a civil conspiracy to encourage targeted appraisals.

The lawsuit remains ongoing but many of the facts that have come to light during the discovery process will be of interest to appraisers. More than any recent case, McSwain’s suit raises troubling questions regarding appraiser independence: namely, how much has changed since the Dodd-Frank reforms?

Appraiser Panels

At the heart of the issue is whether AMCs should create and maintain their own independent appraiser panels or allow lenders to handpick the appraisers they want used on their loans. In an interview with Working RE, Chuck Mureddu, managing director of AMC Quality Valuation Services (QVS), said that QVS uses its own panel.

“We don’t believe in utilizing a lender’s panel because there’s a risk of diluting the independence part of building a fee panel,”

said Mureddu.  (See Low Fee Solution: Cost Plus Model) While independent appraiser panels are not specifically required under Dodd-Frank, many AMCs insist on them in order to safeguard appraiser independence. In fact, StreetLinks’ own Certificate of Compliance, that is issued with every appraisal and is signed by Steve Haslam, StreetLinks’ President and CEO, states that:

“Appraiser Selection was performed at the sole discretion of StreetLinks by utilizing a selection methodology designed, maintained, and supervised by licensed real estate appraisers and is based on the criteria of proximity to the Subject Property, availability, and historical quality and performance metrics.”

However, in legal briefs filed as part of the discovery process, StreetLinks states that it “does not decide which appraisers are included on a lender’s exclusionary or preferred list,” writing that such moves are “solely the lender’s internal decision” and that StreetLinks “has no involvement in determining who belongs on the list, or why.”

Loan Production Staff

A central factor in McSwain’s lawsuit is the allegation that both Yadkin and StreetLinks violated appraiser independence by blacklisting McSwain for his failure to “meet value.” So far, Yadkin and StreetLinks deny any wrongdoing, insisting that their actions are completely legal.

The Appraiser Management Services Agreement between StreetLinks and Yadkin states “the lender panel will be delivered by Customer to StreetLinks…and MUST be sent by the Customer’s operations or compliance department directly from the Customer’s corporate office. StreetLinks will not be required to accept Lender Panel information from Customer’s production or sales staff.”

H

owever, the initial suit filed by McSwain cites emails written by Yadkin’s Branch Manager, and a loan officer, which seem to indicate that direct input on the appraiser panel was made by the sales and production staff. The initial email that refers to McSwain as a “BUTCHER” and demands that he be removed from the approved list for “killing deals,” was sent by Yadkin’s Branch Manager, but it was a Mortgage Loan Assistant who ultimately contacted StreetLinks and instructed them to remove McSwain from the approved list. After confirmation that McSwain had been removed, Yadkin’s Branch Manager then forwarded the email chain to several other loan officers with the message: “FYI, I have had two cut deeply by appraiser,” according to the suit.

According to federal regulations, Yadkin is allowed to manage its own appraiser panel, but influence from sales and loan production staff is expressly forbidden. The Interagency Guidelines specifically address this point, stating that the “collateral valuation program is an integral component of the credit underwriting process and, therefore, should be isolated from influence by the institution’s loan production staff” and “the person who selects or oversees the selection of appraisers should be independent from the loan production area.”

Secret Blacklisting

McSwain’s experience is shared by many appraisers across the country who, without warning, suddenly stop receiving work from a client after a “low” appraisal is submitted. The internal emails from Yadkin provide a rare, behind-the-scenes record of what actually happens when a lender is unhappy enough with a missed value to retaliate against the appraiser.

In legal briefs filed as part of discovery, StreetLinks does not address the removal of McSwain from Yadkin’s approved list, but admits that McSwain was placed on Yadkin’s exclusionary list in January 2013 and that StreetLinks did not notify McSwain that he was placed on any exclusionary list.

“StreetLinks has sent out a BUTCHER on two of my last refis [sic] … make sure he is not sent out in our county and make sure he is not on the approval list…I thought I would let him do these two just to see. NOW THE DEALS ARE DEAD.”

McSwain’s suit alleges that StreetLinks’ failure to notify him of his removal from “its list of qualified appraisers” is against both North Carolina AMC regulations, as well as rules adopted by the North Carolina Appraisal Board, which indicate that AMCs are prohibited from influencing a real estate appraisal by “allowing the removal of a real estate appraiser from a list of qualified appraisers used by any entity without prior written notice to the appraiser” (N.C. Gen. Stat. 93E-2-7 and 21 N.C. Admin Code 57D.0311a). In its discovery answers, StreetLinks expressly denies any obligation to notify appraisers that they are being placed on a lender’s exclusionary list and admits that StreetLinks “has not notified any appraiser that he/she was placed on a lender’s exclusionary list in North Carolina.

It also appears that Yadkin gave StreetLinks instructions to NOT place McSwain on the exclusionary list, but instead to simply remove him from the approved list. However, as part of the discovery process, StreetLinks actually submitted Yadkin’s exclusionary list and it appears that Michael McSwain is on the list.

Regulators Silent

The case remains ongoing in the Gaston County Superior Court and McSwain continues to seek damages from both Yadkin and StreetLinks. It remains to be seen if and when state and federal regulators will become involved in the case. Dodd-Frank defines a violation of appraiser independence as any instance where “A person with an interest in the underlying transaction…attempts to compensate, coerce, extort, collude, instruct, induce, bribe, or intimidate such a person, for the purpose of causing the appraised value assigned, under the appraisal, to the property to be based on any factor other than the independent judgment of the appraiser.”

StreetLinks’ discovery responses seem to provide supporting evidence for McSwain’s contention that he was placed on Yadkin’s Exclusionary List shortly after a Yadkin branch manager referred to him as a BUTCHER and blamed him for two failed deals. According to the suit, Yadkin did not review McSwain’s appraisals for errors or poor judgment and no complaint was ever filed against McSwain for bad appraisal work, nor was McSwain ever notified that he was being removed from an approved list or placed on an exclusionary list. Instead, Yadkin hired other appraisers who submitted appraisals that allowed the two deals to close.

Many appraisers see this case as a clear violation of appraiser independence but so far no state or federal regulators have shown interest in the case. Dodd-Frank mandates a penalty of up to $10,000 per day that the loan exists, so if this case is ever pursued by federal regulators, StreetLinks and Yadkin may each face fines in the millions, since the loans in question were funded in February and March of 2013.

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Isaac Peck

Isaac Peck

Marketing Coordinator at OREP.org, a leading provider of E&O Insurance for appraisers, inspectors, and other real estate professionals in 49 states. He received his Bachelors in Business Management at San Diego State University. He can be contacted at (888) 347-5273.

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24 Responses

  1. jacqueline harris says:

    I am a 37 year experienced appraiser and work with few AMC’s. However I take issue with this article as I have never experienced a negative with Streelinks Lender Solutions. The technology used by SL is superior, by far, to any other AMC. The teams QX Liaison or QX Support are well trained and highly professional. Yes they seek out and have developed a team (list) of appraisers across the country and yes there are metrics you must stay within. But if you are doing your research, complying with USPAP and protecting the public then you will not have a problem. Streelinks is fair with fees and turn times. Bottom line: If you cannot comply with the Engagement letter and Client Specifics “DON’T ACCEPT THE ORDER?’ I am personally sick and tired of the whining that continues. The industry has changed deal with it and do your job. I could tear 80% of the reviews I do apart for lack of overall research. Abstraction, Extraction comments are laughable and not supportive. But hey that is acceptable by Fannie Mae until it is not. No I am not a Streetlinks employee I am a Certified Appraiser who enjoys not having to talk to Underwriters, Loan Officers or Real Estate agents and willing to give up a portion of my fee for that convenience. I also respect myself and my long career so I say “Shut up and do your job correctly then the problem will be solved.” Enjoy you day.

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    • bubba jay bubba jay says:

      oh, i beg to differ. i dumped Streetlinks LS two years ago, and another appraiser friend of mine finally had enough of them this year, and dumped them too. Doing appraisals for 16 years, doing all the research possible, writing two addendum pages full of verbage and explanations, still wasnt enough for them. The constant multiple revision requests over the most insane details, drug out over several weeks, was finally my breaking point. putting up with that nonsense made no sense when there are plenty of AMC’s out there that dont constantly put their appraisers through the wringer like that. i dont miss them one bit. Streetlinks LS was one of the worst AMC’s i have ever dealt with, and dumping them was one of the best moves i EVER made.

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      • Retired Appraiser Retired Appraiser says:

        I shared the same experience with Street Links Bubba.  Once upon a time they were a fantastic company to work with.  They paid well, they would listen to your responses and take note, and they paid quickly.  Everything changed over a period of 2 years.  Their constant demands stressed my office manager out so badly she had to be admitted into the hospital.  They (Street Links) were fired the same week.  Life is too short to endure such stress on a regular basis.

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    • deep south appraiser says:

      I’m with Bubba Jay and Retired Appraiser.  I dumped SL last year.  They were the worst.  They pressured you to “reconsider” the value if it wasn’t what the lender wanted.  The down right stupid and long list of revisions were enough to drive one to the nut house.  I do my research and due diligence, I explain, explain, explain everything.  I DO MY JOB.  In my opinion AMCs are just an extension of the lender, loan production staff, under writers.  I haven’t seen much change since HVCC then Dodd/Frank.

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    • Jeremy Hall Appraisals - Colorado Jeremy Hall Appraisals - Colorado says:

      You lost me at giving up a portion of your fee for that convenience.  You should not have to pay, so that others do their jobs correctly.  IAll grading aside, you know if you raised your fee to competitive levels same as if an amc is not present, all that illusionary grading matrix would not mean anything.  Raise your fee to the same level as you can acquire in the absence of an amc, say; the same fees as the VA pays.  If Street Links still hires you, you’re right.  If not….  Illusionary grading for pretend employees.  Just because you personally have never experienced a similar issue as this article represents, does not make it categorically untrue.  You’re playing advocate.

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  2. Retired Appraiser Retired Appraiser says:

    Robin

    After spending 6 months trying to get appraisal work out of banks I turned to mortgage brokers first.  When a friend of mine went from selling cars to becoming a mortgage broker I visited his office every day.  I eventually became a fixture in the office and was doing precomps for everyone in the office.  Eventually they all began to trust me with my opinion. Many used me for precomps and ordered from others but that was the price I had to pay to get started.  I then started asking those guys to refer me to others.  I took donuts to offices and introduced myself around to every broker that I met.

    From the beginning I churned out reports that would put a legal firms documents to shame; elegant covers and binders, linen letterhead and business cards with raised ink, etc. (Digital document delivery ruined that advantage by the way). For years I gave out dinner certificates to bankers and mortgage brokers who took a chance on me as a thank you gift. I later obtained referral work with a prominent bank through a Title Company by offering them a small referral fees. As time went on we obtained a Class A phone number (252-1000) and paid a little extra to use a nice business address for my mail downtown ($50), before launching a website. Chance meetings later led to opportunities with other banks. After a number of years we worked mostly for banks but I found that they paid less and were more difficult to collect from. When two of banking clients were forced to rotate among appraisers I turned to the internet to make up for the loss rather than pursue any more bank work (see above comment). It worked beyond my wildest dreams for several years. We received so many orders from the internet that we were turning away 9 out of every 10 orders. HVCC killed that golden goose overnight.

    You’re in a predicament. Banks won’t touch you, mortgage companies can’t touch you, and AMC will rape you plus grind you to a pulp. None of these techniques will work today including the internet.  If you make it today it will be based on contacts that you have within a bank…and I’m not talking about tellers.  You are far better off financially doing AMC work through another appraiser than you are doing them on your own.

    Do you play golf with bankers? 
    Do you attend social functions with bankers?
    Do you network with bankers through business clubs?

    If you are truly determined to commit suicide over a five year period these may be the only options you have. The techniques that I used are now illegal or a senseless waste of time.

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  3. Jeremy Hall Appraisals - Colorado Jeremy Hall Appraisals - Colorado says:

    Per article thread;  This is why rotational assignment policies are not just preferable, they are necessary.  In the real world, outside of the illusionary umbrella of governmental control, appraisers are routinely benched, disregarded, removed from panels, and blacklisted for any reason necessary for mortgage production to continue full speed.  A great solution to this is a truly rotational assignment scenario or round robin assignment, coupled with well vetted appraisers whom the assignment company or person is loyal to, for their professional services.  Underwriters should be able to have an influence on appraiser selection, but commission based originators and inexperienced amc assignment reps should not.  It’s up to the lender to run a tight ship, always has been.  The use of an amc cannot save them from themselves.

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  4. All good advice for Robin. Be honest, conscientious, competent and persistent. Also go online or buy a list of AMCS; look them up and do background checks on them (internet). Keep in mid some bad ratings will be from bad appraisers, or the AMCs own competitors.

    On the article thread- We need to legally recognize that removal from an approved list; being turned down for placement on one, and / or blacklisting are all the same thing, parsed differently to side step regulatory constraints. End result is that the a licensed appraiser cannot work.

    I disagree with Jeremy about rotations. I prefer merit scoring if it comes down to that, but I have to admit both have pros and cons. I also agree that some level of QC input from the ‘real client’ is reasonable and rational. We are NOT all the same, and expertise should be able to be recognized and rewarded with more work. Perhaps the solution is the underwriter review as suggested by Jeremy. Seems to make sense-thought hat also has its own pitfalls.

    Maybe we need to reconsider field reviews as well. At one point FIRREA, or an early draft of it called for 10% of all appraisals to be field reviewed. Lenders screamed about costs and delays. Consumers were getting stuck for the fees. Instead, we got second and third tier quality alternatives such as 704 and 2055 drive bys. Like the field review they purported to include most of the same criteria as a review at far less cost (THAT should have been the give away right there). Easily processed superficial secondary analyses do NOT include the depth of research or analysis that a field review does where the reviewing appraiser KNOWS without a doubt there will be a rebuttal; and quite possibly a complaint to the state regulators.

    One thing is certain, when one of every ten reports IS field reviewed and the appraiser KNOWS 10% of their work will be closely scrutinized, the instances of non compliant, poor quality work declines drastically. Back when reviews were common, I used to find 15% to 30%+- appraisals were sub par. Maybe 15% to 20% egregiously so (missed values or other very significant factors affecting value and marketability). When I review them today (for QC mainly) I note about 10% fail basic QC (signed; include correct addresses, right description of interest appraised, etc.). My scope does NOT PERMIT in depth review commenting on adjustments, comments or other peculiar omissions of “obvious questions” raised by facts within the reports themselves. IF that scope were broadened, I suspect the seriously deficient rate would climb to 50% to 75% (though still more reliable than AVMs generally).

    Last item- When a doctor, attorney or CPA makes a mistake; even serious ones, they are not generally punished for human error. It has to be a really serious ethics breach or extremely rare gross negligence issue before action is taken. Then, the penalty is usually remedial unless its an honesty issue. We are different. Make ONE MISTAKE, and an overzealous regulator can take your license and livelihood away. We need to encourage EDUCATION over punishment for relatively minor errors…even when a value conclusion is affected.

    (OK, those that know my posts-you KNEW this was coming!) Join the American Guild of Appraisers (AGA) http://www.appraisersguild.org We are starting to have an impact!  Several minor successes in very recent months that I personally am aware of. We can do MUCH more, but we need your support. Even Bubba Jays and Retired Appraisers. Perhaps especially you folks. Jeremy? Robin?

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  5. bubba jay bubba jay says:

    i think we finally disagree on something Mike. your merit scoring comment is dangerous and i can tell you why.

    what i like about rotations is that it shows no favoritism. you get approved, you are on the list, and everyone gets the same piece of the pie. it also shows no favoritism on the anyones behalf for the appraiser who hits the number all time or the appraiser who doesnt.

    the problem with the rating system as i see it is – if there is an appraiser who always comes in low for example, the rating system could be used against that appraiser because of that issue. now, we can argue that the rating system wont be used in that way, but i will guarantee you that behind closed doors it could and probably does today.

    the system should be pure rotational, and if they dont like an appraiser, then they should get rid of him, BUT he deserves explanation. there are AMC’s and banks i dont get work from anymore. i have no idea why, but i sure the heck cant learn anything unless someone tells me why. i am an honest appraiser and i am a fair appraiser. was i always coming in too low? was i always coming in too high? have i been blacklisted for some reason? i have no clue, and it shouldnt be that way. for any of us. i strongly agree, encourage education and not punishment.

    the bleeding continues . . . . .

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    • Hi Bubba, Wouldn’t it be a dull world if we all felt exactly alike, all the time? You raise valid points…

      I guess I am really still struggling with the unavoidable concept of AMCs still, in the first place. Rotational assignments could work as well as anything else, but they’d have the same opportunities for bias that you and I’d never know about.

      Even if mandated by regulation, the ‘loophole exceptions’ for distance; turn time etc., etc. would still be so big that if an AMC had a client who told them “This guy has killed four deals in arrow, don’t send him anymore” you’d never know it.

      Besides, most trying to circumvent you aren’t even that honest. They’d just make something up about the appraiser being rude, uncooperative, etc.. Last one I had referred to me was out of New Jersey. Homeowner estimate about $100k above appraisal which in turn was only about 25K less than banks owns “guesstimate”. Bank reportedly verbally notified appraiser that owner said he was being discriminated against by the appraiser because he is a [religion deleted] and has an upside down [Icon deleted] on the wall! Even though the entire meeting between owner and appraiser was reported to have been very cordial, with owner even holding an umbrella for the appraiser in the rain!

      How can any of us deal with thinking like that? Rotations, merit or as I like to call it just plain old fashioned competency and professionalism aren’t enough if AMC clients are so heavy handed as to think its the appraisers fault when a deal dies, and that by quiet-listing; black listing or refusal-listing they can change that. Lenders are killing themselves as well. Buy backs are being enforced now days.

      Personally, I think with the vaunted new CU system, that ALL the past HVCC dictated separation between us and loan production isn’t even needed anymore. They are prohibited from influencing us by law, right? So why keep AMCs? Because they are CHEAPER for banks, mortgage banks and other lenders to operate than having their own appraisal departments!

      CU is a “wonder-cure” for FNMA to catch all the high risk (bad) appraisals, therefore why even bother with the alienating separation between brokers and appraisers?

      I USED to be able to honestly ask them “Why do you think its worth “x” dollars? Is everything permitted? Do YOU or the agents involved have any comparable data that you wish to have considered when I come out to inspect the property? To avoid delay, can you bring a copy of the contract or escrow instructions with you? The lender did not forward them. “Oh! You mean to tell me there IS a 1,200 SF PERMITTED addition and completely new near rebuild in the last three months that is not shown in public records? Thank you!” All my preliminary data was for smaller, 60 year old houses. That really saved a lot of wasted time. Don’t you miss the days when we actually communicated with principals or the agents involved in transactions?

      Why even bother having a data source of verification source in the sales grid if they don’t trust us to talk to people without knowing how to avoid being “unduly influenced”? We ALL learned how to say “no” long ago. That or nothing.

      Bottom line? Rotations or otherwise; any system that is not honestly and fairly applied has “heightened collateral risk” associated with the appraisal process.

      Not really sure of the specific answer to the problem.
      Except the blacklisting or refusal to add listings -JOIN AGA! (*G) http://www.appraisersguild.org

      We are fighting that every week. Got a few good things in the works right now. Specifically thinking about over charging appraisers for really minor “offences”. Attorneys can make errors. Doctors can kill people, Accountants can lose your inheritance, Tax advisors can leave you liable for millions of debt yet it is APPRAISERS that have to get hung out to dry???

      Will post more as soon as I’m given ok to.

      Also, Planning to attend TAF meeting in Redondo Beach, CA 6/26/15. Anyone else going? If so, look for the fat old guy with a constant scowl and say hi! Seriously, I only LOOK grumpy.

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  6. bubba jay bubba jay says:

    oh, and your “Last item” comment Mike – dead on. the original purpose of the whole regulatory system the way i understand it, was to go after fraud and serious bigger issues. i had a bad feeling many years ago that as we saw the serious issues dwindle way down and the need grew to justify peoples existence, that the focus would then start moving in the direction of minor things, and i think that is what we are starting to see now. anyone besides me hearing rumors about prosecution quotas? well, there is only one way to accomplish that.

    prosecuting appraisers for fraud and serious offences i can completely understand, but i know attempts that have been made to prosecute/fine and ruin the livelihood of appraisers and their families, because of differing opinions over minor issues and/or lack of a simple comment or two. i can tell you that it does happen, its scary, its ridiculous, and it is a partly to blame for what is driving our people away. and until it stops . . . . .

    the bleeding continues . . . . .

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  7. FLAppraiser says:

    Robin, There’s a guy named (Brian Knowlton Google him for his appraisers blog) who compiles a best AMC list book. He advertises through a magazine pub via Alamode software. One of his mentor associates gives a free online webinar I watched on how to get more non-lender work. ALL THE TIPS and TRICKS used on your webpage to get ranked on the top ot the Google search list no matter who’s pages are out there in your area. It includes things like get Ecard photos of your biz clients on your mobile, start pre scheduled mailer campaigns thanking the client, or marketing the CPA, Use creative funny marketing postcards people will keep, use video testimonial from your happy clients post it on your site, post a google map and a short video on your site, use google webmaster tools and reviews and so much more to receive the highest ranking possible so people find your page. He even builds proven websites for people with all that built in and shows how It works with others he’s done. Non lender work is key to staying busy and maintaining your sanity in this business.

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  8. Jeremy Hall Appraisals - Colorado Jeremy Hall Appraisals - Colorado says:

    In states which regulate amc’s, the list of state approved amc’s is available online as a public data resource, at your states regulatory website. You don’t have to pay for that. Appraiser populace is not keeping up with demand, and you’d better be ready for that volume if you move forward with that kind of web exposure.

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