Category: Federal Housing Administration

Photo of Comps When People or Children Are Present - Standing Rule 48

Did That Guy Just Take a Picture of My Kids?

Looking at the tricky question of taking photo of comps when people are present… I want to talk to you today about something most of us appraisers do on a daily basis – taking comparable photos. Now, I don’t want to get into the whole “Are comps a waste of time? Do they actually serve any purpose?” debate. That’s gone on long enough and it isn’t going to stop any time soon. Instead, I want to try and clear up what is and isn’t actually required from your FHA comps; specifically, we’re going to be looking at the tricky question...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

Influencing Appraisers & Controlling AMCs to Commit Fraud 14

Appraisal Fraud

You might want to read this article. Notice what it says about an AMC allegedly ‘influencing’ appraisers to report incorrect or high values in disregard to federal law about appraiser independence. This brings up a salient point: When AMCs hire and employ W-2 “staff appraisers“, is there a potential for AMCs to direct appraisal value outcomes based on how reports are reviewed and suggested ‘better’ comps provided as a requested correction to a submitted report? But to be fair, this can also happen with lender-based internal appraisal servicing departments, which my first-hand experience proves. It seems that no matter how...

Reform America's Broken Housing Finance System 12

Reform Our Broken Housing Finance System

Hensarling Lays Out Principles for Housing Finance Reform, Expresses Support for Bipartisan Approach “I stand ready to negotiate….with any other stakeholder that shares my belief that America deserves a sustainable housing finance system, and deserves one now.” WASHINGTON – House Financial Services Committee Chairman Jeb Hensarling (R-TX) today outlined reforms to fix America’s broken housing finance system. During a speech at a conference on the future of the U.S. housing market, Chairman Hensarling said he would work on a bipartisan basis to come up with a reform package provided it included certain key principles. He also pointed to a proposal authored...

Surveys Said: 2017 Fee Survey Analyzing the Data 10

2017 Fee Survey Analyzing the Data

Surveys Said: Increasing Fees and Turn Times… For the last few years the appraisal industry has been abuzz with talk of rising appraisal fees and longer turn times. AMCs complain of a shortage of appraisers and “price gouging” in certain markets (Colorado and Oregon, for instance); appraisers report modest success at raising their fees after years of frustration (See Fees Rising). With over 7,000 appraisers responding so far, the results of the 2017 Working RE/OREP Appraiser Fee Survey is a current source for fee and turn time data by market and nationwide. To view the survey results for your market,...

Employees at Quicken Loans... They Delivered Your Pizza! 18

I Must Apologize; I Got it Wrong…

Your employees did not come from Taco Bell, they delivered your pizza! In a recent New York Times article by Julie Creswell on 01/21/2017, former executives of Quicken Loans confirm “many employees come in with little or no background in financial services. One employee joined after delivering pizzas to the Quicken Loans Offices”. No need to say anymore, that statement speaks volumes. The article titled “Quicken Loans, the New Mortgage Machine” is a tell all article, right down to the founder and Chairman Dan Gilbert’s physical altercation on a former colleague at a religious function, to his public tirade against LeBron James,...

Mortgagee Letter Regarding AMC Fees - HUD & the AMC 7

HUD and the AMC

Mortgagee letter on choosing FHA appraiser, AMC &/or 3rd party fees… Does HUD have a Better Understanding of the Role of AMCs? Recently an old HUD/ FHA mortgagee letter has resurfaced. The mortgagee letter, 2009-28 has to do with choosing a FHA approved Roster Appraiser and Appraisal Management Company and / or Third Party Organization Fees. This mortgagee letter specifically states “the fee for the actual completion of an FHA appraisal may not include  a fee for management of the appraisal process any activity other than the performance of the appraisal.” This mortgagee letter was written prior to the Final Rules and...

rainee Appraisers Unsupervised Inspections Allowed: Death Grip on Trainees Loosening 29

Death Grip on Trainees Loosening

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...

Appraisal Regulations - Life After Dodd-Frank ~ copyright AppraisersBlogs 5

Life After Dodd-Frank

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

Transfer of FHA Appraisals 2

Transfer of FHA Appraisals

FHA Case Transfer FHA Appraisers, The document below was issued yesterday by HUD FHA. Sometimes clients will ask appraisers to ‘put the report into the new lender’s name’ if the lender changes within the allowed time frame for a current appraisal. With FHA, the Case Number and the existing report STAYS WITH THE PROPERTY ADDRESS. The appraiser does not have to re-do a FHA report when the lender changes, per this in the document below: Working with Case Transfers Mortgagees should note the following about case transfers relative to appraisal reports in both the EAD portal and FHAC: If, prior...

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