Category: Automated Valuation Models

Increased Regulatory Persecution of Real Estate Appraisers - USPAP 15

Increased Regulatory Persecution of Appraisers

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 37

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response 107

Expert Wants to “Eliminate” Appraisers

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with an industry expert who openly stated she wants to “eliminate” the appraisal profession. No subtlety, no nuance — she wants us gone! Given the name of the website, I didn’t expect to find too many pro-appraiser viewpoints. I ran a search for the term “appraiser” on the website’s internal search engine and many of the articles that came up were about eliminating the profession or the current state of appraisal waivers.…to “eliminate” the appraisal profession…   Rather than read the article...

An Appraiser’s First Impressions of Clear Capital’s AVM 25

First Impressions of Clear Capital’s AVM

An Appraiser’s First Impressions of Clear Capital’s AVM… It’s no secret the lending industry is aggressively pursuing alternatives to traditional appraisals. While most participants in the industry will concede an appraisal is still the gold standard for collateral valuation, they increasingly see the appraisal as something to be steered around or avoided altogether. An array of products/alternatives are being bandied in lieu of a traditional appraisal: Hybrids, Evaluations, BPOs (broker price opinions), Desktop Appraisals, and outright Appraisal Waivers. The industry is also turning its attention more and more to AVMs (automated valuation models). AVMs have been around for nearly three...

The Erosion of Bank Underwriting Standards. Let's Get Rid of Appraisers. 18

Let’s Get Rid of Appraisers. What Could Go Wrong?

Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened. It Is Now Time To Listen Again as History is About to Repeat Itself. There’s a proposal from the FDIC, Federal Reserve, and Treasury Department not to require appraisals for some mortgages under $400,000. The Trump Administration wants to disrupt the role of appraisers, but that’s not a good idea. This change can impact several groups in particular: 1) Consumers: Removing appraisers from transactions can mean a lot of loans get made that shouldn’t be made. Does that sound familiar? We...

Open Letter to Taxpayers... Afterall, Taxpayers Aren’t Stupid 32

Open Letter to Taxpayers

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

Is It Possible to Prove an Adjustment 3

Is It Possible to “Prove” an Adjustment?

We read articles and advertisements on how to prove an adjustment. Is this possible? How wonderful it would be. To prove an adjustment, just push a button and bam! Out comes the correct answer. How could we have we missed this? …prove an adjustment, just push a button…Of course, if such a simplistic and exact answer was possible – anyone could push that button.  An AVM run, a BPO agent, an “evaluator”, or anyone else. Who needs all that USPAP competence and integrity stuff? Even a lender-appointed hybridized “field inspector” could just push the button. The whole process could even skip working with the licensed appraiser completely!...

VREAB to Discuss Concerns Surrounding Hybrid Appraisals 21

VREAB to Discuss Hybrid Appraisals

…concerns on the negative impact on the real estate market… The Virginia Real Estate Appraisal Board Committee on Hybrid Appraisals will meet on Wednesday November 28th @1:00 PM. We ask that all appraisers attend and share your comments on these products. If you are unable to attend we ask that you submit your comments to the VREAB to be shared with the committee. Concerns on if these products comply with: 54.1-2011 which states any assistance by an unlicensed person must be directly supervised by a licensed appraiser. 54.1-2009 Definition of an appraisal which states an appraisal is an opinion, analysis...

Stolen Appraisals Class Action - Theft of Appraisers' Data 87

Theft of Appraisers’ Data

…they charge appraisers an upload fee for the privilege of having their data stolen… I would never allow my data to be used for or by a service that specifically uses to create, modify or enhance products designed to compete with my professional services to the detriment of my business and profession. THAT is something that the Fifth Circuit Court of Appeals identified when they found that CoreLogic’s subsidiary FNC STOLE appraisers data after promising them data security. FNC stole data. We now know FNMA also stole data. Alamode is delving into individuals own personal databases in order to even...

Limbo Anyone? How Low Will Clarocity Stock Go? 10

Limbo Anyone? How Low Will it Go?

No, I am not really going to talk about a Limbo game. I am referring to the stock of a company promoting hybrid appraisals across the country. Representatives of this company are at every industry meeting, promoting their products, often times invited to speak. You are probably sick of hearing about hybrid appraisals by now and honestly, so am I. So I will keep any verbiage about hybrids in the context of reference only and try not to bash them too much. If you are regular reader of Appraisersblogs, you probably have seen many articles about Clarocity Corporation. A quick...

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