What IS a “ClearVal Appraisal”?

Michael Ford

Michael Ford

General Certified Real Estate Appraiser at Michael F. Ford Appraisal
Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory
Michael Ford

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ClearVal Value IS So ClearCut - What IS a “ClearVal Appraisal”Clear Capital ClearVal… Value Not So ClearCut…

I’ve finally had an opportunity to read a hybrid ‘appraisal’ start to finish. All may read the unedited, non-redacted version in all its glory… or infamy, as the case may be. Please click here (report also embedded below) and read it first. I’ll wait right here.

Finished? Great.

One thing is clear. It is not an appraisal by any current accepted definition that I am familiar with. Ironically, there is also very little that is clear as far as support for the opined values is concerned. (I’m old fashioned and think it should be a credibly supported opinion of value – otherwise it’s just a guesstimate – clearly some disagree – read 5th edition dictionary).

Let’s start at the beginning.

The appraisal management fee was $225.00. Of that the appraiser was given $25.00. 10:1 ratio-sounds about par. I’m sure its C&R. Heck, compared to what they pay in Bangalore or Mumbai, India its H U G E!

Clear Capital hybrid fees

Oddly, now that AMCs MUST show the fee split due to an inconvenient oddity of Georgia AMC/Appraisal law they feel compelled to indicate it also covers “Quality Assurance” (really – they wrote that!); Broker/Agent CMA fee, HomeData Index Fee and a Data Entry fee. Their data entry clerk / typist may get more than the appraiser.

Perhaps deservedly.

When they list fees that way it doesn’t sound nearly so negative as listing it under the heading ‘theft of service’ would be.

OK, so for a $25 appraisal fee what do the client and intended user(s) or investor receive?

First off they get a really great appraiser! We know she must be great because she holds licenses as a residential certified appraiser in five states including one the property is located in-even if she isn’t.

That’s right, Florida (FL-RD-5268), Georgia (GA-CR-336501), Iowa (IA-CR-03460), Indiana (IN-CR60901154), & Kansas (KS-3044). For assignments in Florida, Georgia, Iowa, and Indiana her address is in Lake, Indiana, but for Kansas assignments, the address is Hamilton, Indiana. Maybe it was an old one that she forgot to update? I wasn’t able to verify if she has one in Bangalore, India.

Anyway, five different states have seen fit to certify as to her qualifications to complete complex residential real estate appraisals. Let’s all make the extraordinary assumption that she’s highly qualified, OK?

OK, back to the appraisal, or whatever it is. The USPAP Report Option cited is APPRAISAL REPORT. Unless that’s just a teaser, I think it is supposed to infer some degree of USPAP compliance exists.

We also know from page one that the effective date of value was 10/25/2017; and that the as-is market value was $48,000 and the Repaired Value was $100,000 [i].

What we aren’t real clear about is what the definition of As Repaired Value means. According to the not-so-ClearVal Appraisal, it seems to mean something like “The As-Repaired Value Conclusion reflects the expected return on investment of the planned renovations.” It reports that the client provided a renovation ‘scope of work’ with a budget of $34,500.

I guess it’s up to us to try to guess what as repaired value means. My best guess is whatever number they concluded at, is equal to cost of purchase, plus cost of repairs, plus desired return on investment = As Repaired Value. Seems straightforward enough.

Had me going for a minute. Silly me, I thought a desktop valuation would only have one defined value vs one defined, and one we still aren’t sure about. No wonder they use a certified appraiser. This is really complex.

OK, what else does the desktop hybrid by an out of state appraiser tell us? It’s a duplex, and it appears to be occupied despite its C5 rating (C5 means nothing to those appraisers that still use their words to describe physical condition of a property; C5 means ‘not so hot’.

FNMA takes two full pages to translate meaningful English and traditional appraisers jargon into meaningless gibberish. ClearVals apparently forgo such useless translations. Investors the world over either know what C5 means or they don’t care. So they are all on the same page with respect to condition.

Now that C5 rating wasn’t the appraiser’s opinion as near as we can tell. It’s based on an interior CMA inspection on some unknown or undisclosed date by the real estate guy that also did the (only) sales comparison grid adjustments, and the appraiser had no part in that. Did the real estate guy have the FNMA UAD Rosetta stone? By the way, does he need an appraiser’s license in Georgia to opine market value opinions when it is NOT to get a listing?

The Exposure time (for both as-is and as repaired) is 60-90 days.

I’m still a little confused as to how it was listed and sold in only 20 days listing date to appraisal date if the norm is 60-90. It’s probably just me. I shouldn’t do complex math in my head. Besides the report says the listing and contract dates were the same day so whether it’s one day, 60 or 90 days, it shouldn’t matter too much should it?

We also know that the appraiser accepts the estimated repair costs supplied by the real estate agent are a total of $34,500. $8,000 of which was for 2x refrigerator and range/oven. A set-in range and freestanding refrigerator are fully equal to 1/6th the purchase price! N I C E. For that price those personal property items better defrost the turkey AND cook it without human intervention.

Did I mention the duplex, multi family residence is occupied? I don’t know by whom or how many of the units are occupied; what the rents are or whether they have leases, or other rights of tenants in possession and whether these are carry over tenants or new tenants – but that’s probably not important for an income property, right? I mean especially if the income approach is going to get skipped anyway. Besides, maybe in Indiana fee simple means ‘same as rented’? Any Indiana appraisers that can confirm this?

I wonder if all the rents are up to date or whether there could be a rent dispute related to unacceptable “C5” conditions? That couldn’t affect value could it?

Thank goodness there are no externalities! My map shows one of the busiest international airports in the country about 1½+ to 2 miles due north but fortunately the appraisal ignores it completely. If the boilerplate says there are no externalities, who are we to second guess? (Thankfully the MARTA light rail line from the airport to downtown Atlanta isn’t shown on my map or I’d have to wonder about that too).

I’m certain most appraisers will concur that a one-line neighborhood comment description to explain a price range of from $13,000 to $515,000 is perfectly adequate (Tight!). “The neighborhood is in average condition with average curb appeal while having some units in need of minor to significant repair at the time of this report.” …and the Nobel prize for best work in fiction by a new author is…?? Is this ClearVal Appraisal boilerplate or the appraiser’s?

REO Saturation is roughly more than DOUBLE the national average. Repeat sales index is rising. Wonder what they mean by that? Flip prices are higher than prior non flip purchases? Is it local jargon in Truckee California for all ‘residential resales?’ Oh well it’s a nice graph and it probably really does mean something about the market value of the subject. Attractive use of color too!

Listing history and prior sales.

No prior sales shown in prior 3 years. I couldn’t find any either – but then I’m not familiar with Georgia transactional reporting. Wonder why they auctioned the property.

Listed, but no analysis provided. Listed and contract entered into first day. Auction reported by Atlanta appraisers familiar with circumstances. Sale price was $48,900 with a new first Mortgage in the amount of $77,790 – private party financing 12/13/2017 (post effective date). Picture is becoming clearer, I think.

The $48,900 also is reported to have been a multi parcel transaction. In my state that means more than one assessed land parcel – not sure what is means in Georgia (All claims to the contrary I don’t truly speak ‘Southern’). “What if-ing” $77,790 needed; 80% LTV minus a couple points means it HAS to be worth $100k “as repaired”, right? Probably just a coincidence. Suggested value isn’t in the order and no one would ever have thought to make a phone call, would they? Especially since the as repaired value is so ClearCut.

Now, here is where we may run into a sticky situation. Appraisers in Atlanta that have read this report and performed perfunctory data checks didn’t find the 20 comparable sales the Indiana appraiser referenced. Being from the heart of America (Indiana), maybe they have better “comparable” sales data there than Georgians do.

Damned locals are probably talking about other comparable single duplexes or triplexes rather than bulk sale bundled property comps like the appraiser reportedly used. Picky, picky, picky! How come 3 or 5 duplexes sold as a single deal can’t be used? How about if we only take pictures of the front of ONE duplex each and make believe they are all ‘duplex’ just like the subject?

It would be unfair of me to be critical of using five duplex comps or three duplex comps without being the one preparing the appraisal so let’s skip over that and move on. It’s not a problem if we don’t point it out, right?

We know that (from the report) that the four very best and closest comparable sales were used. Um Oops, I mean the three very best sales and a listing were used. Some were similar to inferior in age, some superior to similar in GLA (as long as all those pesky alleged extra units aren’t counted). That’s not counting the strange & peculiar things the agent showed in his CMA.

The reported sale at 5570 Windwood represents the “as-is” value (all by itself); and a sale at 5607 Windwood and listing at 5631 Windwood tell us what the “as Repaired” value is; and presumably the sale at 4377 Springwood Terrace is there to keep the others company? But not real close company.

S3 is the highest of all sales and is from well out of the neighborhood about 3 ½ miles away. That’s ok if no better comps are around, but I’m not sure I’d reconcile to an out of area sale when the best IN-area comp is saying $83,000.

I’m trying hard to replicate the steps: $83,000 + $111,000 = $194,000/2 = $97k mean; hit it with a big hammer and kick it in the rear end and conclude at $100,000? Um, yeah, sure.

OK, don’t be snarky Mike! Maybe out of area S3 was weighted slightly more for unexplained reasons. Sales 3 ½ miles away that ARE directly under the airport flight path probably have a premium? I know I’d enjoy sitting on the patio waiting to see if I can catch bits and pieces of passing aircraft in my old Stan Musial autographed baseball mitt. What I DO know is that an $83K unadjusted same-street sale does NOT support $100,000-at least not as shown.

Maybe this isn’t actually an appraisal at all! MAYBE it’s only supposed to be one of them “Reconciliation” thingies the title companies used to love to hustle. Take two meaningless sets of numbers and merge them somehow to get ‘something different’? Call it an appraisal-hybrid as opposed to what President Truman would have called it.

The appraiser refers to her ’grid’ though I suspect she means her unadjusted one-line comparables’ list. To me a ‘grid’ is short for sales comparison grid and I assume adjustments appear there. Her one sale that ostensibly reconciles to $48,000 sold for $36,250 (we think). As I already noted, I’m not so good at doing math in my head but I would think a sale at $36,250 would support something in a range of say $35K to $37K -maybe $38K+/- range without making adjustments. Did I miss something?

OK, interim summation before everyone loses interest:

Appraised market value of what we think may be a leased fee interest being considered as fee simple was $48,000.

Appraised “As-Repaired-Some-kind-of-Unspecified-Expected-Return-(ROI)-Value” $100,000.

I hesitate to comment or inquire about the CMA ‘comps’ undefined “fair market value” since the appraiser does not indicate reconciliation to any of those results. Presumably they are in the report for some purpose. None of them support the concluded value (as repaired) though all are higher than the ‘as-is’ market value concluded for the subject.

The listings include one on the subject street which might have been interesting to do an actual analysis on. Owned by the same owner developer by any chance? How long on the market?

None of the sales show any sales data or verification sources. In the spirit of camaraderie shall we assume everything is hunky dory as reported by either the appraiser or the real estate guy with no other verifications needed? (Hey! I just figured out a way to speed up ALL appraisals!) No more time-consuming verifications, OK?)

Pssst! Highest and Best Use as if vacant and as improved is ok to just assume, right?

Same with adjustments. Phone the guys over in India and ask them how much to adjust size, location, age, quality and condition for; or lay hands on the keyboard; or use divining rods and conjurin’ to find adjustments and market values!

We also cannot tell when the real estate agent inspected the property. The pictures (pictometry) are dated February 13, 2017 which lets us know what the overhead aerial views were around 8 months before the effective date. Not much else known.

Some appear to be current (see interiors) and one appears to be before the ‘as repaired’ state (windows boarded up and or broken).

OK as with all reports, maybe there are some plausible explanations for all these things.

Scope (or claim) was to satisfy “interagency appraisal and evaluation guidelines.” I especially like Limiting Conditions #2 (LC2). Assumed to be current and accurate unless specifically found to be otherwise – presumably by their quality assurance people? LC3 is kind of cool too! LC6 is another good one worth reading. LC7 disclosure is governed by USPAP and the bylaws of professional appraisal organizations with which the appraiser IS affiliated? LC9 is another one – infers repair estimate is “based on the appraiser’s desktop analysis”- it appears on reading the report that the analysis was limited to reading the agent’s CMA and concluding after much consideration and intuited-impression to “Yeah, what he said.”

Certifications – may be more problematic – Statements of fact are true? Like comparable sales data? There have been several credible reports that MLS details for the comparable sales that were used tell a different story than is shown in the hybrid.

Cert 8 is one that I will let my peers opine about as to adequacy. The report does claim to be USPAP compliant.

I ran a public records closed sale check around the subject. My greatest concerns if I were doing an appraisal of the subject is (1) why are almost all immediate area sales (under 1/3 mile distant) seemingly LLC purchases in this area with double national average REO saturation so long after the recession? (2) Was that ONE $15,000,000+ sale the raw land subdivision due north between the subject area and the airport – east of Crystal Lake? Why would it pop up as a similarly sized comparable property sale? Outlier – or significant factor in current neighborhood market activity?

Readers must decide for themselves – credibly supported opinion of the (two) values claimed? So, what say the peer appraisers?

Is it wonderful work and a credit to our profession, or fodder for state regulators and possibly CFPB? For $25 bucks are lenders and their investors getting what they think they paid for?

Information developed post appraisal is that the owner was not able to obtain an appraisal at the hybrid value ($100,000) in order to pay off the existing loan & investors. Was he mislead by an inflated potential value?

I wonder why an income analysis wasn’t deemed necessary in order to develop either of the values concluded. Is a one-comp-sales-comparison adequate for “as-is” values now? No income approaches. No cost approach needed?

I think if I were an investor at ‘Ground Floor’ I’d be wondering if this is covered by anyone’s E&O insurance. Heck if I were the buyer I‘d be wondering the same thing.

Electronic signature-plausible deniability? Nah – NO WAY you can hide the kind of paper trail fees of $25.00 creates.

Click here for the second hybrid report.


Footnote: [i] “When repairs are noted and the appraiser has concluded a Repaired Value conclusion that differs from the As-is Value Conclusion presented in [this] report, the Repaired Value Conclusion is predicated on the hypothetical condition that the stated repairs have been completed as of the effective date of value.”

 

Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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149 Responses

  1. pt says:

    Complaints should be filed in EVERY state named herein. This should also go to the sec, FTC, and the fhfa.

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  2. Eric Kennedy says:

    Wow – great work Mike Ford. How much did you get paid for this review and article?? 😉 I know… 0. Thanks for your time and resources.

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  3. Betty C. says:

    Been verified says her phone number is 219-448-0697. One of Appraisal blogs “Breaking News Correspondents” should ask her for an interview !

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    • Baggins Baggins says:

      Appraisal subcommittee search brings better results.

      https://www.asc.gov/national-registry/findanappraiser.aspx

      “Catching” the appraiser seems inconsequential. The amc directed this approach, they promoted this activity, probably in large scale nationwide. The amc’s name appears more frequently than any other party in the report. The lender is also noted, it would seem that an appeal to them might result in the swiftest corrective action.

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    • There have been complaints sent to AB all from the same ISP claiming different false email addresses saying appraiser has been receiving threats. I don’t believe its true, buts lets remember folks, we will lose whatever credibility our research earns if someone actually does start threatening harm to an appraiser; or even rude comments resulting from posts here. Lets be adults folks.

      Rather than making a phone call, just file a state complaint. Indiana does it online – though you will have to explain some inapplicable sections. Georgia required a notarized signature (worth the effort in my opinion).

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  4. Xpert says:

    Great work Mike! I feel like I’m in the Twilight Zone…

    “Michelle Shoven, an appraiser that does everything… To other appraisers she’s the most unwelcome addition to the industry…but without her you’d never enter the Twilight Zone…”

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  5. Pattie P. says:

    Wow ! I guess the geographic competence issue is old news now !! She has one hell of a territory !

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  6. Appraiser says:

    $25 for two opinions of value? What a deal! You get what you pay for. This product is not credible, not USPAP compliant. And Clear Capital is again stealing the lions share of the “appraisal fee.” This appraiser has sold her soul to the devil…..she’d better check with her E & O. Shes going to need it.

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  7. Scott R. says:

    $25 as an appraiser or $100/day as a Walmart Greeter. See me waving?

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  8. Rick G. says:

    A copy of this should be sent to the Georgia State appraisal Board in a formal complaint. Let’s see if she can back up her analysis.

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  9. Here is the link to a second hybrid report completed by the same appraiser.

    Look at the labels for the interior photographs. When you look at both reports, 5557 Winwood Rd (discussed by Mike Ford above) and 906 Silverwood Dr, linked below, the same photographs are used with different property addresses labeled on them.

    Clear Capital ClearVal Hybrid Report 2

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    • Rob Decker says:

      The reports are virtually identical except for the subject address. This will be the coup de grace. Put her out of her misery.

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    • Baggins Baggins says:

      Also, it appears the map is re used, and several interior photos are re used but cropped down so as to trick picture matching software. Clever! The appraiser merely reviewed a cma and relied on Earl’s data. This is remarkable to see this posted online. How else to expose what quickie products are all about. Earl should be complained on first?

      Undoubtedly this is the tip of the iceberg regarding systemic deficiencies in quick and short form products.

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    • Ya mean we can’t use the same pictures and just ‘adjust’ the photo labels to suit each report? Darn! That’s inconvenient. It could slow down the entire desk-appraisal-‘value-added’ manufacturing industry in five entire states!

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    • ERIC S KENNEDY says:

      Lot’s of nice “data”..   but does it have ANY “Credibility”??

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  10. Jan Roseberry says:

    They are purchasing your E & O Insurance! Better check to see if you are covered.

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  11. Baggins Baggins says:

    Where is the appraisal?  This is a rubber stamped cma provided by a realty agent.  The appraiser signs as a reviewer at the end of the certification. An appraiser reviewing cma’s? Per ASC, this individual appears to be licensed in 5 states, several very recently. That’s quite the coverage area.

    Likely related, via search for agent.  As usual, the largest companies are the most aggressive, pushing the envelope of ethics and acceptability.

    With over 1,500 Associated Brokers and Agents, PalmerHouse Properties is the 10th largest Georgia real estate brokerage in 2016 closing over $1.32 Billion. PalmerHouse Properties has recently expanded to Florida, North Carolina and Missouri.

    http://palmerhouseproperties.com/?aios_agent=earl-farmer-jr#

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    • Rob Decker says:

      Actually there is no signature on this report or its fraternal twin. There is a line that says appraiser and the name is typed in Michelle Shoven. Then there is a line that says digital signature and that appears like this   /Michelle Shoven/.  I guess that is how you think you are going to keep your license. What? I didn’t sign that. lol

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      • Report says ‘electronic signature’. I think thats even worse. is she affixing or authorizing it each time or is ClearCapital just slapping her name on these without her specific authorization? You know, like a $25 signature licensing fee.

        Any bets we won’t hear back from Clear Capital at all?

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  12. don says:

    Isn’t the biggest crime the lender accepting the appraisal from the loan agent?

    Historically investor-bankers were protected by recourse lending. Most industries have defense clauses written in making both parties to the contract responsible. Some how our legal system has favored some one over another, as do politicians. Recourse lending was awkward and slowed the process, most investor-lenders were unhappy and it disappeared in the mid 1970’s, tooo badd.
    Don 

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    • Rob Decker says:

      This is a crowdfunding outfit. They are like a REIT’s baby brother taking “nickles and dimes” from non accredited investors.  Groundfloor talks big, but now we see the dark underbelly of this beast. I have it on good authority that after this flipper was funded by Groundfloor, he couldn’t get an appraisal to “make value” for him to make a profit. In fact, he was taking a bath and offered a bribe of 3K to the next appraiser to come along to hit a number.

       

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  13. Tim says:

    It appears Clear Capital got just what they paid for… I can only pray that this “IDIOT” (SORRY BUT THE ONLY WORD TO DESCRIBE HER) loses HER LICENSE & GETS SUED

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    • Baggins Baggins says:

      Don’t forget about Earl.

      Audit time, how many similar products has clear capital approved, for how many different clients, in what states, and is failure to identify these obvious inconsistencies in reports a penalizable offense towards amc licensing?

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  14. Scott R. says:

    But wait a minute. If a person were to actually look at the Clear Capital web page it states (and it’s on the internet so it must be true: “Our network of more than 40,000 boots-on-the-ground field experts deliver deep insights so you can proceed confidently in all your real estate decisions. 

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  15. Steven says:

    The appraiser is likely an employee or staff appraiser for the AMC, licensed in multiple states, and she probably never even saw the report. Her name was simply cut and pasted on to the report, never signed, as you can see from the “electronic signature.” 

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  16. Diana N. says:

    Absolutely disgusting, and an insult to hones, hard working appraisers everywhere. Hope they throw the book at her.

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  17. Wayne Courtney says:

    Any appraiser willing to work for $25.00 needs to be retested!

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  18. don says:

    Did a lot of foreclosure appraisals over the past 57 years, never had a lender nor the VA provide the original loan appraisal. just goes to show whos got the power.

    don

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  19. MD appraiser says:

    If I come across any report like this one in my state, I will forward it to DLLR and file a formal complaint.  I think she should be turned into each of the 5 states she’s licensed in.

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    • I downloaded the Georgia Board complaint form. It has to be notarized so I will have a friend do that tomorrow. Will also file complaints in Indiana and maybe AMCs home state. The other three states would only be if one of he other states finds shortcomings. I don’t think they have jurisdiction otherwise.

      Additionally maybe CFPB and we have already communicated with authors of recent SEC investigation articles. MY hope is that every person that reads these will ALSO file complaints. If they get four or five complaints on same person on same issue they will have little choice but to open investigation.

      Imagine what they would do if they get a hundred or two hundred?

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  20. Eric West says:

    This is so wrong on so many levels and totally worth an investigation!

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  21. SaraK says:

    Absolute disgrace to our profession. This makes my blood boil! Utter disgrace

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  22. Matt Schorle says:

    To be clear, I’m not defending this product, but no one on this blog has an issue with the author, and now the Appraisalblog team, posting a confidential document with NPI to a public forum? Let’s use USPAP to bolster our argument against this appraisal, but accept a black and white breach of the genesis of those governing standards in doing so? Unfortunately, this could result in legal implications for those parties. As an appraiser myself, I find this an abhorrent hypocrisy.

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    • Desiree Mehbod Desiree Mehbod says:

      Matt, you obviously know nothing about Mike Ford. Why don’t you read all the articles he has authored on this blog, and then go browse his website (http://www.mfford.com). You can also do a google search. Once you know more about him, please do come back here and let us have an educated discussion about his character and caliber.

      Just FYI, Mike Ford is a valued member of our industry and spends countless hours helping, mentoring and supporting appraisers throughout the nation, and he does it VOLUNTARILY. Appraisers are fortunate to have the support of this outstanding appraiser, and such a caring and committed individual.

      If you truly are an appraiser, (it appears you are not per asc registry), you may consider putting your energy in joining the rest of us fighting the low fee structure, consumer price gouging by amcs, amc blast orders for the cheapest and fastest appraisers regardless of their knowledge of the local markets, qualifications or competence, poor quality products (such as the hybrids posted here), meaningless micro management by amcs where the vast majority of their employees don’t know anything about appraising, endless 20+ pages long amcs’ engagement letters, appraisal waivers, etc… to name a few of the issues negatively affecting us and the consumer.

      It looks like this is the first time you are commenting on this blog. And your first comment is to attack a fellow appraiser and not just any appraiser but an appraiser who has always maintained the highest moral and ethical standards. Where have you been? And how come you’ve never commented against hybrids, notorious amcs such as clear capital and all issues affecting our industry?

      My guess is… you are just another amc troll and not an appraiser. We get a lot of them here.

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      • Matt Schorle says:

        Desiree, I honestly respect your well articulated post, and you’re right, I shouldn’t have disparaged Mike. I’m sincerely apologetic to him for doing so, and to Rick G. below…..and to anyone else I seemingly offended because my opinion on this matter differs from theirs.

        I fully understand the obstacles of our profession, and yes, I’m an appraiser and also doggedly seeking ways to stay relevant in the evolving valuation world. However, I find it completely unnecessary and abhorrent to crucify an unsuspecting peer on a public forum like this. Are these really the actions of someone who seeks to help their fellow appraisers- someone with the highest moral and ethical standards as you claim?  Not to mention, posting confidential information that we have been entrusted by the public and our clients to protect. Does that not have repurcussions for our industry?  How come these issues aren’t debated intelligently by anyone? Why is it that a fee for an assignment an appraiser accepted the true underpinnings of such attacks on a human being? I make business decisions not to complete various assignments everyday, I would never deliberately hurt those that need to take them for various life reasons.

        I know I’m alone here, and I accept that, but at least I have the integrity to defend my peers against wrongdoings- even if that means I suffer reproach. I’ve said my piece…..Good luck!

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    • Matt, number one, there IS absolutely zero confidentiality obligation on any of us. NONE. IF there were any NPI obligation its on the part of the appraiser and the AMC.

      They should have been aware that down the road the owner of the property that purchased it based in part of their desk appraisal’s as repaired value might become upset enough to make the report public when it wouldn’t appraise for what they claimed the repaired value would be.

      People have already been harmed by these two reports.

      Aside from that, I have no intention of standing idly by while MY profession is undermined by liars at ClearCapital claiming this garbage is USPAP compliant (Yes, I INVITE their attorney’s contact or other interest-truth is an absolute defence!). These appraisals weren’t required to comply with USPAP as FRTs; maybe Georgia requires it? What I do know is that they do not get to claim USPAP compliance if they don’t actually comply. Deceit and lack of credibility are not compliance.

      Further, maybe they do these online in effort to avoid paper trails floating around that can be set in as complaints.

      I am very careful about how I parse any article where I am accusing anyone of actual wrong doing. When I do so it is with full understanding that I am at risk of retaliation. In this instance I have only posed a series of questions. Readers can make their own decisions.

      Our profession is not going to clean itself up. Bankers aren’t going to do it. FNMA sure as hell wont do it. Congress probably wont do it. TAF has no desire to do it. ASC doesn’t seem to have the will, mandate or authority. So who IS going to try to do something?

      What about the investors that BELIEVED they had a USPAP compliant professional appraisal? The same investors that may not get paid off because the property wouldn’t appraise for the desktop value?

      (There is much more behind the scenes that is known, but which isn’t being published because that would jump into speculation and other issues).Both appraisals were from same original source. I simply only had the one with the second being verbally communicated to me regarding same pictures and verbiage. Its inclusion is proper, in support of claims that BOTH products have serious procedural issues and credibility issues. Some readers might even say basic honesty is in question.

      Matt I think we are ALL unhappy that disclosing this stuff is even necessary to begin with. I don’t enjoy it. Every minute I spend on this kind of thing represents money I am not earning for myself or MY family; but I think its important enough to warrant the trade off. I’m also a taxpayer that never wants to see another TARP.

      …and lastly I’m a ‘little guy’ that is frankly just fed up with being screwed over by “too big to be held accountables” pissing on my leg and telling me its rainfall. Enough!

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      • Matt Schorle says:

        Well said, Mike! I appreciate the respectful response. Best of luck!

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      • John Galt says:

        I disagree, I also believe you’re obligated as an appraiser, which we’re defined as an institution under the law, to protect the NPI in that report. You said you were given the report from a consumer, that means you’re accountable under consumer safeguard laws.

        Complying with the Gramm-Leach-Bliley (“GLB”) Act

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        • ERIC S KENNEDY says:

           
           

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        • John Galt says:

          I found this whitepaper from The Appraisal Foundation, it offers some insights as well.

          http://www.dennisbadger.com/seminars/USPAP/ASBPrivacyGuidance.pdf

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        • John You are simply wrong. About what I can do; what an appraiser can do and what NPI  is and how it may or may not be used and who can authorize its release.

          I have zero obligation to protect anyone related or associated with the appraisals in question. I did not say I was provided with them by a consumer. I said they originated with the consumer. These reports actually went through several sets of hands including people they (involved parties) were trying to influence before reaching me. But either way, your understanding of NPI and restrictions on its use are erroneous. (By the way, a consumer can absolutely choose to make their own appraisal reports public). Parties that shown these as part of a larger effort to unduly influence, may also share these.

          Now, the original appraiser (Ms Shoven) CLEARLY was bound by confidentiality. I’d even argue the AMC and their client was as well (with respect to themselves). Their obligation to protect the NPI was to their client.

          I HAVE NO CLIENT in this case. I am a member of the public that has had wrong doing brought to my attention. I am under zero obligation to protect the ‘confidentiality’ of those associated with products that purport to be one thing (USPAP compliant in this instance); or even appraisals in support of purported market value – which turn out to be something other.

          I actually spoke to attorneys today about Qui Tam filing (not these cases specifically – merely illustratively of whats going on with GSEs as well as lenders like the ones involved here). Make no mistake John, ‘we’ are collectively looking for samples of similar reports used in FRTs and those will most certainly become ‘public’.

          Potential class action suits are not off the drawing board either. You know all those AMCs that like to micro manage the entire process and use auto-annoyance messages? A good number of them may have crossed lines even for us as ICs.

          If lenders; AMCs, REVAA and anyone else doesn’t want to figure prominently in public articles about the quality of their or their clients work product(s) then ALL THEY HAVE TO DO IS STOP MISREPRESENTING what those products are.

          It’s real easy to avoid being the focus of these kinds of articles.

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          • John Galt says:

            I see your point, and I’m trying to piece this together through this thread, so forgive me.

            Based on what I’ve read about the GLB, it’s still your responsibility as a financial institution to protect NPI. They define appraisers as a Financial Institution, and bound by privacy and confidentiality, no matter where they fall within the chain. The law specifies loan #’s, client information, and interior details as NPI. A consumer can indeed make their information public, but a loan number and client name isn’t theirs according to these laws- it’s the client’s and need authorization to be released. Therefore, it’s an appraiser’s duty to determine what information can be considered NPI and required by law to redact it.

            If your reasoning is correct, that means any appraiser can obtain any other appraiser’s work and distribute it with no questions asked or repercussion. Also, you publicly rendered an opinion of that appraiser’s work, which can be interpreted as an appraisal review and subject to USPAP.

            I totally support your mission, but I don’t think doing it this way will be effective. I do admire your fight!

            If the industry wants a more cost effective and quicker value option, what can we as appraisers do to meet those needs? Proving these are unreliable is easy, but that doesn’t offer a solution. That solution should come from us.

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            • John-Matt-Lisa or whoever you are (Michele?) Now you’ve crossed over into Looney Tunes Land;

              Where in my profile does it indicate Im a financial institution? As for my correct reasoning, YES. ANY appraiser that has legally come into possession of an appraisal report CAN make it public. Period. It is the originating appraiser that has an obligation to maintain privacy of NPI. I have dozens that I’ve been given over the years as representations of bad work. The reason none of those has ever been made public is they were good enough to maintain the illusion of being real appraisals and my advice to those sending them to me was either file state complaints or in four cases file state complaints plus ethics complaints with AI; or accept the existence of the bad work. There was no direct & immediate public interest to be served by publicizing them.

              My understanding is that in these two Georgia cases, the owner finished all his planned renovations and wanted to refinance out of the short term loans. When the new appraisers came out to inspect the property the owner offered these appraisals in support of his strongly expressed desired value. They and anything they contained ceased to be NPI at that point.

              There was reportedly some additional conversation that is purported to entail improper and undue pressure on the appraiser that was doing the inspection. (Actually considerably more to it was reported but I wasn’t there for the conversation so wont report it as factual).

              The issue is: A phony appraisal was (2 actually) were prepared using a flawed system and process that does not remotely match Clear Capital advertised quality claims or reliability. An out of state appraiser was paid an inadequate amount to actually do the job properly that USPAP requires (since they were claiming USPAP compliance) & GOT CAUGHT doing crappy work. (And that’s putting it nicely).

              All your phony arguments about alleged third and fourth party obligations to maintain a privacy level not preserved by the original appraiser OR AMC themselves are merely feeble efforts to distract from the real issue. That is “ClearVal Appraisals” as demonstrated by these two reports are worthless, do not comply with USPAP and appear to misrepresent values to the point where the original borrower may well have legal recourse to all parties involved. Whether the investors that loaned the money will also make claims is anybodies guess. We can only hope.

              I’ve filed a formal complaint with Indiana and Georgia follows later this week. Then, after consulting with others, a decision gets made about filing a complaint with the states the AMC is licensed in. There may be jurisdictional issues.

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          • John Galt says:

            Also, if you had no legal obligations, then how did someone obtain the legal authority to have it removed from this site? Copyright law suggests an owner can do with it what they wish. How credible is your source?

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            • John Galt, aka Matt Schorle,

              getting Scribd to remove a document is very easy. All one has to do is fill out a short online form. Scribd doesn’t usually take the time to verify the validity of the claim but gives its members the possibility to dispute it.

              No real person has contacted us directly to have these documents removed. Lisa G tried to post false claims using fake email accounts and different fake names. We emailed this person for more details and our emails bounced back.

              Only you and Lisa G (probably the same person) seem to have an issue with this. Lisa used a fake email address to comment in the first place and you started posting as Matt Schorle, pretended to be an appraiser, then switched to John Galt.

              Mike has already responded to you several times regarding confidentiality. It is best to move on and agree to disagree!

              Please understand that guest trolling is not tolerated. Anyone coming on here to spread misinformation, disrupt threads to further a personal agenda, attack others, start flame wars, or get their jollies by sockpuppeting, et cetera, will be banned!

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              • Baggins Baggins says:

                Get em! Mission accomplished. Sort of. 

                Now to alert every single regulatory agency in every single state, such trickery is likely happening right under their noses, courtesy of clear capital. Oh heck, everyone knows already, amc’s get a free pass and are literally above the law.

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            • John-Matt no one obtained the ‘legal authority’. A supplemental services provider simply removed it based on an unvetted complaint as is their policy. It wasn’t worth ABs time to argue with them since they can store the reports using alternative storage sites.

              John you have chosen to deliberately distort and misrepresent both issues as well as your own background. You talk about imagined legal obligations that you have no clue on. Look at the thumbs up/down ratios. Do you really think you have persuaded anyone here?

              By the way, when you are pretending to be the Georgia appraiser you should use a completely different computer from a location outside of MA where you and Matt share the same ISP.

              As for my source their credibility is not in question at all since the crappy “appraisals” speak for themselves..unedited and as presented. All the diversion in the world will not change the FACTS that those two reports are spurious with no hint of credibility in any aspect of them.

              Look up the broker who ostensibly prepared them. You think a guy that owns and operates 12-14+- offices in three different states, and seems to be a pretty big deal brokerage is actually going out and inspecting these properties himself? Let me help you John-Matt, the answer is a resounding “NO!”

              So, the appraiser doesn’t know the WHO or even the WHAT of qualifications or the source of data she signed her name under.

              Hopefully enough readers will send letters direct to the property owner and suggest he contact attorneys to see if he has a possible fraud claim against the broker-appraiser of AMC that assembled the “ClearVal Appraisal.” Maybe an E&O claim against the appraiser for the inflated values. He certainly doesn’t need to have an attorney to file a complaint in Georgia, Indiana and California (where the AMC is purportedly located).

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  23. Lisa G says:

    I agree, Matt, I know my clients wouldn’t appreciate this at all and I’d be in pretty hot water if I ever did this. There was no need to post the actual files with loan numbers and use the appraiser’s actual name. Does anyone know Michelle?

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  24. Pt says:

    Guess what….this is not an appraisal so no breach of confidentiality. Guess what, this reaction is exactly what third party vendors do not want…..sunshine that is now exploding across the country. For 15 years our rules have harmed Appraisers and consumers AND assisted lenders and their agents.

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    • Matt Schorle says:

      Guess what…..this IS an appraisal as it’s a value rendered and signed by a certified appraiser……Guess what….this a proprietary report obtained by a client that has a loan number and borrower name……So, you think posting this NPI to a public site BY AN APPRAISER doesn’t harm the consumer?…..again, not defending the product, just pointing out the obvious hypocrisy of this author’s self-fulfilling prophecy.

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      • Rick G. says:

        I doubt this will harm anyone but the reputation of the sell out appraiser that did it for $25,  the predatory lender that is the intended user, and this opportunist appraisal management company ( just about the worst one out there ) that was engaged.

        GUESS WHAT….. ?  We are at war ! You  have to sacrifice a few to save the many ( many consumers that will be harmed by this crap ). Thanks for posting this Appraiser Blogs and whoever shared it with the author thank you too! It’s time we lift up the cinder block and expose these predatory lenders and appraisal management companies for the insects and parasites that they are. Matt is most likely one of these sellout appraisers that has no work because he’s not good at what he does, an AMC troll or CEO.

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        • Matt Schorle says:

          Hahaha. “We’re at war?”….”You have to sacrifice a few to save the many?”……You’re as dim as the author. You’re a perfect example of why this profession is dying and why those who need valuation services lament using appraisers. I really regret I have to be lumped in with myopic practitioners like you.

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          • Rick G. says:

            Lumped in with me ? Blah, ha, ha ! Your obviosly “lumped in”elsewhere ! Ha, your as crooked as Clear Capital and as ” myopic” as the goof ball, weak ass appraisers that are doing these ! If the profession is dying it’s because of people like you and this “appraiser” who are not fighting for it.

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            • Matt Schorle says:

              Amazing! You honestly think this initial post is fighting for our profession. All this does is hurt us, all of us. As I clearly stated, I’m not defending this product, Clear Capital, or AMCs- I’m voicing my issues against this obvious violation of our confidentiality requirements as appraisers to the public. Just imagine if sensitive client information you were legally obligated to protect was disseminated on the internet without your knowledge. You have taken a USPAP class, right?

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              • Steven says:

                If the report was provided to Mike confidentially then there may be an issue between Mike and the provider.  I don’t believe that Mike would have posted this had it been given to him confidentially.

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                • Matt Schorle says:

                  Hi Steven….I feel the author could have made the same impactful argument without publishing the actual report to the internet. If he really wanted to be a steward and voice for the appraiser community, he should have been ethically responsible and did what’s right for all of us. It’s hypocritical to claim full appraisals are needed to protect clients/consumers by causing harm to that very cohort.

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                  • Steven says:

                    I don’t disagree Matt, I probably would’ve redacted some of that information before posting if it were me. In this case I don’t see any wrong doing from Mike or the Appraisersblog team though. Obviously this AMC or the lender/client released this report to unauthorized parties before it ended up here. This is because most AMCs employ individuals who don’t know the meaning of the word confidential and they will deliver the report to anyone who simply calls and asks for a copy.

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                • Thank you Steven. It wasn’t (confidentially provided). The provider had full advance knowledge of what I would do with it if and when it was sent to me, if after reading it I concurred with original discussion comments concerning it.

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      • BigAl says:

        Matt, how long have you been appraising and which state do you work in? The reason I’m asking is because your name does not appear in the asc registry.

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        • Matt Schorle says:

          Hi BigAI- I’ve been appraising resi since the early 2000’s and complete assignments in the northeast- I don’t work for an AMC. How about you?

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          • BigAl says:

            Then why aren’t you listed in the asc registry?

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            • Matt Schorle says:

              Who said I’m not? And why are you so concerned with uncovering my personal information? It has nothing to do with this dialogue.

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              • BigAl says:

                It absolutely does. I’m not trying to uncover your personal information. Just your professional information.

                Matt Schorle doesn’t exist as an appraiser. There is no record of you as an appraiser in the asc registry or anywhere on the world wide web!

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                • Matt Schorle says:

                  Matt is my middle name and my last name is abbreviated. Regardless, my name is not germane to this discourse.

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          • Matt do you do any of those appraisals under a valid state appraisers license for real estate?

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            • Matt Schorle says:

              Yes I do.

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            • Desiree Mehbod Desiree Mehbod says:

              Mike, he is not an appraiser.

              He stated that Matt is his middle name and his last name is abbreviated.

              Well I did a partial information asc search for last names.

              The are only 2 Northeast appraisers with schor in their last names and both are females: Paula in NY and Kelly in MA. See screenshot of the asc search results below.

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              • Matt Schorle says:

                Wow! I guess participants don’t have any right to privacy on this forum…… Trust me, Desiree, I’ll never post here again, this is now getting a little scary.

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                • Desiree Mehbod Desiree Mehbod says:

                  Matt,

                  Why scary? This is what we do as appraisers. Research and investigate. You don’t even sound like an appraiser.

                  Trust? I’m sorry but I can’t trust a misleading individual.

                  As for whether or not you want to post here, I could not care less one way or another. It’s your choice. But if you do, know that you cannot come here and pretend to be someone you are not, attack a valued and respected member of our industry without being scrutinized.

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                  • Matt Schorle says:

                    Desiree- my original comment was not an attack; however, I do admit, and have apologized to Mike for, some of my subsequent comments.

                    I am an appraiser, not a troll, not a CEO, and not an AMC. I simply wish to remain anonymous, not unlike others here. It’s scary to me that multiple strangers are trying to find personal information on me. I’m assume those intentions are to cause harm, why else would someone put forth the effort….

                    Anyway, good luck!

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                    • Cool. Nothing wrong with anonymity; and contrarian views have as much place here as those that are on the opposite side of them.

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                    • Desiree Mehbod Desiree Mehbod says:

                      Matt, it wasn’t much an effort. Just a simple search on the asc registry.

                      You ask why else? Because amc trolls pretending to be appraisers are a dime a dozen here. And their sole purpose is to disrupt normal conversation and pit appraisers against each other.

                      You should have been honest off the bat and just said you’re using an alias or that you want to remain anonymous instead of “Matt is my middle name and my last name is abbreviated”.

                      No one here is out to get you or harm you. None of us started this. Just go back and re-read your comments. You came out all guns blazing and you sounded just like the amc trolls we’ve been dealing with on a regular basis.

                      Regardless, please let’s stay on-topic and not make this personal. Appreciate your apologies to the other commentators. If you want to help, please file a formal complaint. You can find forms for investigations against both the appraiser and broker in question at http://www.grec.state.ga.us/forms/investigationforms.html.

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                • Wayne Courtney says:

                  Matt, I know how important privacy is to those on this forum. I sure would hate tor anyone to know that Wayne Courtney is my name. If folks cannot find me I suppose I need to increase my advertisement budget! LOL…I can be found in TEXAS!

                   
                  No $25.00 appraisals please.

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                  • God Bless taxes? Seems like funny lyrics for a song but those folks over in Texas sure looked like they were having fun. Kinda glad Appraisers Fest will be there now.

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                    • Wayne Courtney says:

                      Hello Mike,

                      I have tried to research the Appraisers Fest you mentioned above. I did find that is was to be held in San Antonio in November. So far I have not found many details. Do you know if this is being sponsored by a professional group of appraisers or an AMC circus with the usual clowns? Thanks for any info!

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                      • Eric Kennedy says:

                        No AMC’s allowed at AppraiserFest Nov 1-3 or on the FB page 100% Real Estate Appraisers which founded the event. Look it up and ask to join – you will be vetted before entering, as only Appraisers are allowed.

                        I was at the AARO conference in DC last year and there were more AMC reps there than actual Regulators. REVAA has mice all over DC and we have NO representation while our Independence is truly being taken advantage of. WE need a voice and Voice of Appraisal is also a founder of the Fest.

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                      • Hi Wayne – See Erics post.

                        Sign up with FaceBook group 100% Appraisers. Its a closed or private group started by Mark Skapinetz. Mark screens all applicants to assure they are appraisers. I think all you really have to do is send him an email and maybe a few questions. Its a closed group to maintain the integrity of discussions about issues and avoid undue influence from folks like REVAA and other non appraisers.

                        It simply different than ABlogs is. I personally prefer the issue focus that tends to prevail here; and the ability of non appraisers to offer views when appropriate. The other is more diverse-Social (fun) ; some help, some snarkiness and some infighting but mostly informative. Some light hearted silliness to take the edge off bad days, too.

                        All categories of appraisers from cmml-agricultural, rural res.; rural cmmls, sub divisions, sfrs, etc. I think its worth joining (both there and here).

                        Though it is AB that devotes more space to specific issues usually.

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                  • ERIC S KENNEDY says:

                     
                     

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                • Baggins Baggins says:

                  Matt, this website is under constant sophisticated technical attack by middle management companies.  Billions of dollars a year is a mighty large pie to take, amc’s want it all as evident by this articles disclosure.  If you want to be anonymous, just do so obviously.  Trolling here is very real and often nefarious.  Please give the board the benefit of the doubt.  You’ve taken a position of defending those who would put you out of business.  Not exactly a readily defensible position.  This appraiser fell on her own sword, welcome to the new era of accountability and actual transparency.  Personally, I think give appraiser light slap on wrist, and immediately sanction the amc nationwide along with heavy penalty to realty agent who obviously cheated on his cma.  The matter in question is a cma, not an appraisal.  I don’t care what they call it, affixing an appraisers name to a cma does not make in an appraisal.  Lighten up, you’re not the one who’s going to be in trouble, the perpetrators of this fraud are, and rightfully so.  Think of the fair balance and differences between outright fraud and deception vs simple disclosure to counter improper and recent standards board advisement vainly trying to legitimize these god awful industry destructive products and practices.

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                  • Matt Schorle says:

                    Thanks Baggins! I completely agree these products are horrid- I’m sure the industry will see that rather swiftly. I’m an appraiser too, not trolling and randomly defending people as many on here seem to think. I do appreciate your respectful post.

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              • BigAl says:

                HOME RUN Desiree!

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      • Actually it isn’t signed. It has what is alleged to be an electronic signature and we don’t know if Michelle SHoven authorized use of her signature on these or not. Nor do we know what parts if any were attached after she signed it electronically (assuming she actually did). Her phone number is listed in ASC directory (twice) if any want to call her.

        Mine is (714) 366 9404 Feel free to give it to her. As for all your other hyperbole about NPI – the second the property owner gave this to us for use it ceased to be NPI. Even if it were, WE have no client relationship with the pondscum that produced the format used. We also have no obligations to the specified client who themselves MAY have issues of wire fraud to deal with down the road.

        As for harm to the consumer it was the consumer that supplied the reports.

        Your post would also have FAR more credibility if the ASC national registry had any appraiser with the last name of Schorle. You and Lisa work for the same AMC by any chance?

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        • Matt Schorle says:

          No, Lisa and I don’t work together, and, again, I’m a field appraiser.

          So, if you didn’t know if the appraiser actually signed the report, then why post her information here and use such derogatory tones against her in your diatribe?  Did you not read the spewing of disgust against this person you provoked?

          Can you provide everyone here the name of the “client” who provided you the report? Can we contact them? Do they know you posted a report with loan numbers to an online forum?

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          • I said the consumer provided the report to the sources that gave it to me. I assume you can mail him at the property. The client is shown in the report. Go ahead and call them. Im told ClearCapital that ordered this is out of Truckee California. They’re on the internet. Feel free to send links to the post to their attorney or their Chief Appraiser. I’ll be filing formal complaint(s) tomorrow as I indicated in earlier posts.

            I’m also still waiting to hear from Georgia appraisers about whether a broker can provide an opinion of Fair Market Value in Georgia that was clearly not for use in obtaining a listing.

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  25. Hooligan says:

    If Matt is correct and this IS an appraisal I sure would like to see the AMC’s documentation that a the fee paid to the appraiser of $25 is anywhere close to being reasonable or customary. Despite its limited format and scope of work. How much did the field inspector get paid? More or less than the appraiser? My fee in Virginia for a final inspection is between $100 to $150. No analysis and very little liability. Just a simple status report. Give me a break.

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    • Matt Schorle says:

      The name of the broker who completed the inspection/BPO is in the report too. Might be worth reaching out- I’d be interested to know that too.

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      • Matt – couple thoughts, if the name is a nom de plum please just say so because there is no “Schorle” licensed in ASC directory. Its a credibility issue. Its fine on AB if you choose to be anonymous – just not fine to be deceptive. If you are an appraiser under another name that chooses to keep it private, no problem and no criticism (from me anyway).

        I just got off the phone with Dustin Harris. He and certain other I also respect oppose ‘outing an appraiser.’ In most cases where REAL appraisal are performed; I’d tend to agree (barring really apparent gross deception and misleading issues). NONE of us do such perfect work and we can’t all be found with an “i” that isn’t dotted or  a’T’ left uncrossed. For those that know me, those are exactly the kind of cases that we at AGA spend most of our effort trying to help appraisers defend themselves.

        These reports are very different. Amid all the hype about how USPAP compliant alternative appraisals ‘can be’; the fact is that NONE have been posted anywhere that actually ARE. Redacted or otherwise.

        Some time ago First American tried to push a product called a PACE PRO (desktop type) that had the probable fraud built right into it. It was so bad even ASC and FFIEC had problems with it. It too labelled itself as being USPAP compliant.

        So, what started out as questionable ‘alternative’ products at around $75-$100 proposed fees became actual orders offering only $10 if done in India, to $25 in these samples. Right now it is my contention that no qualified appraiser can competently perform these type appraisals to USPAP standards for out of state property for $25.00.

        BEFORE these reports were ever published considerable discussion was held behind the scenes involving at least four appraisers I am aware of; at least two of which that had direct knowledge of ALL the circumstances (even more negative than those I posted).

        These specific cases involve issues that need to be brought before regulators attention to take care of the problems before the entire profession of appraisal loses whatever limited credibility it still has. By that I mean specific complaints need to be filed. Can’t do that against “name redacted.”

        There is also an issue of jurisdiction: Best information right now is that NON FRT intended use via Ground Floor (client) in support of internet or other wire communications offered crowd funding has produced at least one inflated value. Inflated enough so that the investors that loaned money through the crowd funding will not be able to be paid off as promised.

        1. Is this an issue for SEC and FTC, or only CFPB?

        2. The appraisals are labeled as being USPAP compliant. Given other short comings of these reports, this could amount to fraud charges that could involve both multi office statewide Georgia R.E. Broker (who also has offices in Florida and Missouri I believe) and potentially the appraiser. [no such claim is being made] – we honestly don’t know if signing appraiser ever actually authorized her signatures use. She may thank us for bringing this to her attention; or she may choose to offer other explanations refuting what we see here.

        3. Even non FRT appraisals that claim to be USPAP compliant are within the jurisdiction of the state where the values are opined. The fact they they appear to have been performed in Indiana may bring that state into play. Each state has its own jurisdictional limitations. This has a separate potential for becoming another federal regulatory concern. Whose rules apply? The state the property is in or the state the appraisal is actually performed in?

        Trying to keep this a purely philosophical discussion would defeat the purpose which is to effect meaningful corrections. It is also to let appraisers that participate in this low quality level work know that there will be repercussions. IF no appraisers (or AMCs) ever have to worry about being held accountable, then THIS kind of work will become the norm for the profession.

        Few here would survive the competition from unfettered appraisers and agents allowed to produce these things with impunity. Another question is whether this is actually a CC staff appraiser; one where CC paid her out of state license fees, or simply guaranteed a high enough volume to make signing whatever was put in front of her worth while.

        I encourage all readers to also look up the rokers name and check out his website. This is a BIG brokerage. Multi state. Does anyone seriously think this specific guy inspected each of these properties? Or, do we have a “trusted delegated” third party inspector who in turn is also reassigning the BPO inspections?

        Credible results & honest disclosures or not?

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        • Matt Schorle says:

          Mike, thank you very much for this concise and respectful response- I sincerely appreciate this. I’m not debating the quality of these products, they’re obviously flawed and should be used in a very limited capacity. I’ve been reading voraciously about them and my understanding was they’re used for portfolio management or developing marketing plans- not lending. My concerns with your original post surrounded the NPI (loan numbers) and putting a fellow appraiser in the crosshairs of scrutiny- I personally feel that’s wrong on a public forum. You said yourself, you were given the report by the “client” and you weren’t sure the appraiser even signed it. Who knows if it were manipulate in anyway at some point, but that’s purely conjecture and really why I would have removed her information. Either way, I’m hopeful her reputation isn’t tarnished beyond repair. As an appraiser (yes I am one and do seek to remain private), I do align with your mission to promote our worth to the industry.

          Again, I’m deeply sorry for some of my comments toward you above; I’m disappointed my frustrations got the best of me. This was a very humbling lesson.

          Good luck with this endeavor!

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          • I respect the opposing view though I disagree with it in these circumstances. Absent naming the players this keeps going on forever and all we have is a philosophical discussion. Filing complaints may bring remedial action. That’s the objective. I just filed the Indiana complaint online. Georgia is logistically more difficult – that will be tomorrow. I urge all to do the same.

            No false accusations. Just the actual known or believed issues. Let the states decide if there are regulatory issues.

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          • Baggins Baggins says:

            The massive profiteer army of unlicensed inadequately or non experienced individuals in order assignment both ‘direct’ and amc, have rendered the vast majority of mortgage origination appraisers as the lowest common denominator, judged purely by fee and turn time, promoting wreckless behavior and demoting honest self sufficient laborers.  This industry has shed over 100k licensed highly experienced persons in favor of unlicensed unaccountable ‘managers’, and will shed the remaining 80k licensed appraisers in short order if hybrids, waivers, and an increased de minimus come to fruition.  Distributors nationally have stole the potential of many careers in favor of unregulated unrestricted fee skimming.  All too many are not respecting management rules to not provide a thing of value to be the preferred selectee, it’s been a problem for a long time, enticement by discount to rake unfair portions of work ahead of more worthy candidates.

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      • Joe Appraiser says:

        Matt –

        Agreed, someone should do that

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  26. Baggins Baggins says:

    Looks like CC used copyright infringement and pulled the document.  Hope someone printed it.

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  27. LOL !!! They only did it through the SCRIBD link-the second property appraisal is still embedded in article above.

    Im ok with them arguing copyright infringement though its spurious. This was given to appraisers by the owner and its posting here is not for any commercial purpose. Id argue it’s in the public domain. I’d never expect others to put their necks on the line for my posts though.

    Having said that-Kudos Des! I see ones still up above!

    I’ve filed complaint with state of Indiana already; Georgia tomorrow. I forgot to mention it in one to Indiana but I wonder if the Georgia Real Estate Broker violated Georgia MLS services copyrights of their pictures; and whether CC violated Pictometry copyrights for using theirs in a commercial appraisal report?

    I almost forgot about Georgia’s requirement that all appraisers be paid C&R fees according to their schedule or alternative methods. I dont know of any studies where 10% is deemed C&R. Thank you “Hooligan” for the heads up, Mike

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  28. Baggins Baggins says:

    Amc’s wield disproportionate unanswerable power and effectively dominate the field of individually licensed persons without restriction and without restraint.  They do what they want, they take what they want, and they buy whom they want.  They are not accountable, not as individual persons, and not as companies as a whole.  I’d join a class action but unless I’m part of a larger group of protection, I dare not go against these highly corrupt domineering organizations. They have ruled through intimidation for 10 solid years now with little to no consequences.  Lack of individual licensing in amc’s has lead to a culture of dominance and disrespect to the fields these companies initially claimed to serve.  They’ve already literally cleared out half of this industries workforce, claiming those monies for themselves instead. Now primed to replace the rest, capture the complete whole of the valuation service industries income potential, eliminate licensing in general, actively advocating towards those ends daily.  These companies have been more effective at eliminating checks and balances than any criminal I’ve ever heard of.  True boiler room operations.  Lord, where was the exit again, soon now, very soon.

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  29. Hard to believe this is the promo piece/ad for the product we saw posted here.
     
     

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    • Baggins Baggins says:

      “Our inspections are completed exclusively by licensed real estate agents or brokers,” (However, management of these professionals requires no such license, specialty, or experience base, also paying on average 5x as much.)

      “One of the key components is the panel of licensed or certified appraisers who are “powering” the product. These appraisers have completed over 375,000 Collateral Desktop Analysis (CDA) reports to date”

      (375k instances of confirmed disproportionate fee skimming not in compliance with C&R rules.) What’s the RegZ penalty again, 10k/20k, per instance, per day, or per both? When is anyone ever going to enforce C&R rules?

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      • Baggins Baggins says:

        375,000 x $225 = 84,375,000 dollars. Considering the total fee is likely half of the traditional base fee for valuation service products, double that amount to consider loss of income in the appraisal industry due to these aggressive predatory practices. Approximately 168 million appraiser earning dollars absent due to the aggressive nature of these products, and that does not even consider the much larger portion of fee skimming and unearned fee raking. Undoubtedly harming local communities and instead funneling profits to the elite few in charge. Repeat after me; appraiser shortage, appraiser shortage. Obey. Consume. The product being manufactured is you.

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        • Baggins Baggins says:

          Has anyone put together industry wide estimates regarding how much of the pie amc’s have taken by now, and their populace counts?  They’ve grown so large with armies of employees and lobbyists.  In other industries such monopolization and underhanded dealings would have already brought forth audits and financial investigations.  No rules for amc’s, they are the bitcoin of real estate now.  Tyler.

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  30. Baggins Baggins says:

    So what, they’re just getting away with it and the only penalty was this article?

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    • Baggs, I’ve already filed a complaint with the Indiana Board. I went to see a notary friend but forgot to take the Georgia complaint with me. I’ll take care  of that later this week. Also, need to get original borrower (property owner) to see if he wants to file complaint with CFPB; and / or go after appraisers E&O.

      I suspect no one else will do anything. It would make an impact if more complaints were filed but I’m not holding me breath on it.

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      • Baggins Baggins says:

        Well if amc’s had not already made it clear as day they will take punitive action against appraisers for standing up for themselves…  These companies are powerhouses of pressure and deception, true boiler rooms with virtually no individual accountability.  You provide a truly invaluable service to this industry however it’s questionable if this industry will hold up.  In 10 short years the amc’s grew to monolithic giants whom dominated the landscape over all others, avoiding disclosure, individual accountability, and licensing on every turn.  Their growth is now accelerated and it’s likely the appraisal profession will cease to exist in mortgage lending unless every single last distribution employee is held individually accountable through licensing.  That may be the final solution, the only solution.  The question was rhetorical, they have already gotten away with it.  375,000 evals already completed per the companies own advertisements.  This escalated quicker than any of us initially realized.

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  31. Scott R. says:

    We (appraisers) need a Nancy Reagan style “Just Say No” campaign directed at unscrupulous AMC’s. I was a lender/VP at a regional bank for many years before becoming a real estate broker and appraiser. Before our bank would approve any money being loaned out, common sense dictates a lender hire a real appraiser with eyes, ears (boots on the ground) to personally inspect an asset. How and why the lending industry has been moving away from this common sense approach defies logic.  

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  32. Baggins Baggins says:

    Money for nothing with no individual accountability is a powerful motivator.

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  33. Joe Apprasier says:

    Just another way for the big corporations to push out the appraiser

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  34. Hooligan says:

     
     

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  35. Hooligan says:

    I think the VA is smart enough to see what is going on here.

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    • Baggins Baggins says:

      But as amc’s have absurd flex cash, they will simply pursue normal avenues of approach, lobbying, bribing, and strong arming their way to victory. They have already won, the appraisers just are not understanding this yet. We are helpless in the face of major corporations and their employees whom have no personal accountability. The 10k/20k fine set was supposed to put them all out of business. As not a single instance of this ever materialized, it’s time to admit the law has not been applicable to appraisal management companies. These destructive companies put 100k appraisers out of work in 10 years. That’s 10k a year on average, or roughly 835 a month, or about 27 a day.  Turns out the argument they’re destroying the host were incorrect. Amc’s have purposefully driven licensed appraisers out of business, in hopes of capturing the entire valuation income pie for themselves with vastly reduced accountability and liability. Vulture capitalism at it’s finest. This is the end game. These companies expanded at record paces which exceeded actual known ponzi schemes, to business sizes exceeding well established major corporations with far more infrastructure employees and overhead. It is my understanding that to date not a single one of them has ever been audited or held to compliance with the majority of lending rules which everyone else has to follow. Prove me wrong.

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  36. I don’t look to tilt at windmills and win every battle.It’s more like dropping a pebble or pebbles in a pond and seeing where the ripples go and for how long. Sooner or later one is large enough or far reaching enough to attract the attention of enough people to do something.

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What IS a “ClearVal Appraisal”?

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