Is the FTC asserting that FNMA is exempt from antitrust laws? I don’t think of myself as being obtuse, nor do I think those that know me well would consider me to be particularly slow of wit or comprehension. Despite this, I’m truly confused by the Federal Trade Commission (FTC) attorneys response to the American Guild of Appraiser (AGA) email letter we sent them. The first sentence states “The federal antitrust laws prohibit anticompetitive mergers and business practices that seek to prevent hard-driving competition, such as monopolistic conduct, attempts to monopolize, and conspiracies and combinations that harm competition and consumers.”...
I am heartened that the Federal Trade Commission has recognized the need to assure that appraisal “…consumers deserve to benefit from a free market where those fees are set by competition.” It appears that your complaint may have been instigated by the very special interests that are most responsible for suppression of appraisal service free trade and fair price competition in America today. By that I am referring to the entities broadly described as Appraisal Management Companies (AMCs), and in this specific complaint – the Federal National Mortgage Association, also known as Fannie Mae and/or FNMA .
FREE Cost Approach calculation worksheet… Appraisers, Many use Building-Cost.net as a source for completing residential Cost Approach details in appraisal reports. Craftsman Book Company is the owner of this service, and the web site offers a FREE Cost Approach calculation worksheet, which can be printed to PDF and included in reports, and also a printed hardcopy for the workfile if desired. I began using and promoting this web site years ago. Not long ago, the web site above was updated, to provide more specific reporting items, which in turn enables a more accurate and professional looking Cost Approach to be...
Amendments to Sales Contract & Updates to the Appraisal… Fannie Mae recently issued the following: Currently, we require the lender to provide the appraiser with all amendments made to a sales contract, including amendments that are made after completion of the appraisal. With this update, we have clarified when the appraiser must be provided with updates to the sales contract and circumstances that warrant updates to the appraisal. For example, if the contract is amended in a way that affects the description of the real property used by the appraiser, then the lender must provide the updated contract to the...
Very often the public records are dead wrong… Appraisers, We all know Fannie Mae (FNMA) has their Collateral Underwriting (CU) report scoring system after the .xml file of the report is submitted through the Uniform Collateral Data Portal (UCDP) portal used by both GSE’s. This system of theirs is used to ‘score’ an appraisal for a loan quality rating, and it’s also used to provide a lender with a guarantee of relief from a FNMA loan buy-back demand, if the report ‘scores’ a number of 2.5 or lower. We’ve previously discussed how that can be manipulated by a lender or an...
These forms were “designed” to be used for those specific purposes… Appraisers, Earlier this week, I discussed the following about some lenders requesting a type of property inspection to be completed on a form “Not Designed” for the specific property type: Original observation discussed earlier this week: Read the highlighted sentence. Read the highlighted sentence again. According to a regional bank in my area, via info from their AMC, “thousands” of Manufactured Home appraisals have been done on the 2055 form. Do you do that, just because someone – who just wants to “make a sale” – tells you to...
If the ‘story’ can be told using 3 comps, why are 4 or more really necessary? Folks, As you are probably aware, all of our appraisal reports receive an initial examination electronically. There are a number of businesses which have written and provide to the industry various types of ‘rules check software.’ This actually began in the early 1980’s by the appraisal computer software pioneers who wrote programs to ‘check’ reports for inconsistencies. I just learned about one such ‘rules check’ company, and the results they’ve seen using their software – below. They even admit to users that the users can ‘mine’ reports...
About half of AICPA members don’t believe in USPAP… When I first heard that “they” were trying to do away with the Appraisal Practices Board (APB) of the Appraisal Foundation (TAF), I tried to keep an open mind. I also wondered who “they” are. Did the Appraisal Institute (AI) finally get a sympathetic ear in Congress? Was it preemptive action by the Board of Trustees in anticipation of budget cuts by the new administration? By the way, what does the APB do? I certainly had it wrong. I thought they helped develop the Advisory Opinions (AOs)! To be candid the...
Congress, cut FNMA loose from conservatorship and let them sink or swim… Every day I tend to agree more and more that we are facing an uphill battle against corporate America. Then I remember that as a former Marine, I’m supposed to be ‘ok’ with uphill battles. We make do with what we have, not necessarily what we want or need. Add to this most, if not all of our Congress from both Senate and House. Some isolated exceptions but most either don’t care or encourage the weaknesses in the financial system for their own gain. There is a reason...
Allowing associated trainee appraisers to complete unsupervised inspections… Appraisers, and others, A ‘significantly large’ nationwide AMC has notified it’s vendor appraisers that certain lenders contracted with this AMC will now accept appraisal reports signed by properly trained (and presumed properly approved by the State) Trainees as the ‘Appraiser.’ This follows the Jan. 31, 2017 FNMA announcement that they will accept reports signed by Trainees. So far, I have not seen any similar announcement from FrMAC, FHA, VA, or USDA, or any other specific lender. The AMC’s message to their appraiser panel is below. NOTE: This memo says the Trainee is...
