The CFPB is reviewing bias in Automated Valuation Models (AVMs). The proposed rules are a joint effort by the Consumer Financial Protection Bureau, the Office of the Controller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Federal Housing Finance Agency. These agencies are concerned AVMs may reflect bias in design and function. The mathematical models rely on biased data resulting in inaccurate valuations. Basically the agencies are stating historical data going back to redlining is built into these models and do not reflect current market data. Remember markets are not static and are...
…I’ve discovered a potential anomaly in Desktop reports (and Hybrids also) which might shock some appraisers… Desktop Appraisals, Panaceas for Faster Reports. Or so they say. Bankrate.com has a revealing article published on Oct. 27, 2021, titled As Appraiser Shortage Delays Closings, Mortgage Giants Try Workaround | Bankrate FHFA (the GSE’s “manager”), after the administration change, under pressure from mortgage brokers and lenders, and after the experiment with the COVID era “flexibilities”, has decided to allow the GSE’s to accept a new type of appraisal for first mortgage (purchase) lending early in 2022: the Desktop report. The current line of thinking...
The desktop appraisals are not necessarily more reliable, which could become an adverse issue for appraisers in the future… Appraisers, we learned about this late on Monday, Oct. 18, 2021: Sandra L. Thompson, acting director of the Federal Housing Finance Agency (FHFA) appeared before the Mortgage Bankers Association annual conference on Monday. Her remarks to that group featured this: The “flexibilities” (i.e., the desktop appraisals) put in place for appraisers after COVID-19 hit, have ended. However, FHFA has been reviewing the data gathered during their use and examined feedback from lenders and other parties. She told the MBA attendees that both...
What once was a ‘three year’ project to redesign and implement revised appraisal forms has morphed into one taking far longer. Actual implementation and use of ‘new forms’ are not scheduled to happen until (presumably) early in 2024, but could be extended even further. By 2024, the currently used ‘forms’ will be 19 years old, and the current UAD overlay entering ‘teenage hood’ at 13. For context, the current Planet Mars Perseverance Rover mission to successfully plan and land scientific instruments took only 9 years! Details for the ‘forms redesign extension’ are based on the announcement from Fannie Mae (and Freddie...
FTC vs LREAB Update The Supreme Court has denied the Louisiana Real Estate Appraisers Board’s petition to intervene in the administrative case for price fixing by the FTC. The FTC trial is scheduled to proceed on April 20, 2021. VaCAP is closely following this case and will update you as it proceeds. To view all the activity for this case, go to the FTC’s webpage here. Working RE Appraisal Survey Let your voice be heard on what is customary and reasonable fees for your services. Working RE is conducting the annual fee survey. We have been asked to help distribute...
The most weighted technique in most automated valuation programs comes down to one over-simplified formula, based on a guesstimation from an outside source that has no interest in the real estate system… Dear FHFA: Please accept the following comments in regard to Question A1.4. The response also includes comments on several additional questions. Thank you for taking the time to review these thoughts. Technology has made so many improvements in the last decade and we now have the chance to truly improve our home valuation system. With that being said, the last piece of the quality puzzle starts at the...
If we value higher, what about affordability?… A great deal of economic, social, and political talk has been around affordability of housing. To explore this topic, it may be helpful to ask some questions. Good policy starts with the right questions. In simplest terms, some people have the resources to have nice homes in nice neighborhoods, others have just tolerable homes for shelter. And others have no homes at all. We call them “home-less.” More recently, we have become aware of the connection of poor housing and groups of certain ethnic categories. Discovery. There is association between housing status and...
Why FHFA thinks the GSE’s should be even discussing appraisal processes is a question that needs to be asked of FHFA… Appraisers have let others dictate many things in our profession. It is time to stop the trend… How about 20 questions? The Federal Housing Finance Agency (FHFA) has 20 questions for you. Well, actually it is only 19 questions. The FHFA is the organization of the Federal Government that oversees Fannie and Freddie. They want feedback on how the GSE’s should move forward with appraisal policy, risk and appraisal processes. Now why FHFA thinks the GSE’s should be even discussing appraisal processes...
Who’s REALLY completing bifurcated/hybrid appraisal reports? This essay has been “rattlin’ around my cranium” for a few months from the time I acquired two ‘case study’ report examples in early 2020. I’ve recently received a third bifurcated report, which has similar appraiser data. So now is a prime time to spill the beans, so to speak. Especially since FHFA, the conservator of Fannie and Freddie, is currently on a mission to “modernize the appraisal process.” They are seeking input from appraisers and other stakeholders who use appraisals. But first, as the infomercials say, there’s more! One ‘more’ concerns appraiser obligations...
The appraisal professions should be the only ones to determine any modernization; whatever that is… When Things Don’t Go as Expected Like so many others, I have learned the hard way not to accept any assignment without a little due diligent research first. Make no mistake I do not shy away from difficult assignments. I am under the firm belief the more difficult, the better. I actually enjoy the challenge. I recently accepted a private assignment over the phone for a lot in the City. I was driving and did not have access to MLS or locality records. I knew...
