Computershare Reviews & Cheap Diapers
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This didn’t start out as an article, but you know me. Doing research prior to posting in the 100% comments board I was shocked at how pervasive this new ‘service’ already is. A simple blog post can’t begin to cover it.
Every single reader needs to research their own states requirements. The AMC at the following link makes this easy. Please look your state up.
My concern was with Computershare and Colorado. Feel free to look them up by clicking here.
If that doesn’t alarm you click their recent acquisition link (Lenderlive).
Here is the issue:
No competent ‘servicing’ corporation or AMC could possibly think USPAP compliant SR3 appraisal reviews can be performed in either 15 minutes; or for $15. Let’s not even address whether their online proprietary form is SR4 compliant.
To suggest 15 minutes is all that is needed for compliant reviewing indicates that they are not remotely professionally competent to be reviewing anyone else’s compliance with USPAP. Or, for that matter, to be managing anyone’s appraisals in any other way.
It’s not possible for me to fly if I go outside and flap my arms repeatedly very, very fast. Numerous predecessors throughout history have tried before me. Heck, as a kid I even gave it a go while jumping off the garage roof in first grade. It just doesn’t work.
Similarly, I also KNOW it is impossible to perform a competent SR 3 compliant R.E. Appraisal review in 15 minutes. I don’t need to jump off that specific roof again to know that. I’ve done many hundreds of SR 3 reviews in my career; and even more internal QC ‘reviews’ long before the proliferation of post HVCC AMCs.
I’ve also purchased very low-quality diapers for my daughter when she was young. Once.
The resulting “outcome” of those cheap diapers is the same outcome as Computershare 15-minute reviews must be.
Will they also be hidden from all public scrutiny? Will appraisers be able to subpoena the work files when their professional reputations are irreparably harmed?
Thanks to VaCAP for bringing this out for public scrutiny.
VaCAP sent me a news article with a particularly alarming message in it. Their original source insisted on anonymity, and I chose to redact the Computershare author’s name as well. It is on file if needed by any state authorities.
15 questions are numbered for similar reasons.
From: [redacted] <[redacted]@computershare.com>
Sent: [redacted*], August 2*, 2019 **:** AM
Subject: New product request
Hi [Redacted Appraiser Name],
I work for Computershare and I have been diligently looking for appraisers to complete to do our NEW USPAP reviews (Information provided below, and the list of questions are attached).
These pay $15 per report and are completed in 10-15 minutes. We utilize our own form and the reviewer answers 15 USPAP compliance (Yes or No) questions on the appraisal. Please let me know if you are interested. Thanks so much for considering this.
The Regulatory Compliance Review (RCR) is:
- A review of an appraisal for state AMC licensing compliance.
- Appraisers completing this product are not required to provide a value.
- A signature is required to complete the report.
- The form auto-populates text and data to cut down on the time spent.
- The RCR is designed to be completed within 10-15 minutes.
- The expected turnaround time is 6 days
Valuations Analyst > Loan Services > Property Solutions
T 303 895 2769
8742 Lucent Boulevard, Highlands Ranch, CO 80129
From VaCAP’S news article – the content/attachment to the above email:
I have been diligently looking for appraisers to complete to do (sic) our NEW USPAP reviews. These pay $15 per report and are completed in 10-15 minutes. We utilize our own form and the reviewer answers 15 USPAP compliance (Yes or No) questions on the appraisal.
The 15 Questions are:
- Did the appraiser provide all necessary State disclosures (fee statement, AMC information, etc.)?
- Did the appraiser exhibit competency in performing the assignment with the specific property type, value amount, in compliance with applicable zoning and market influences?
- Was the appraiser’s scope of work reasonable and sufficient to deliver credible assignment results?
- Did the appraiser identify the client? Intended users? Intended use? And real property interest being appraised?
- Did the appraiser identify and employ the correct methods and techniques in this appraisal assignment?
- Did the appraiser analyze agreements of sale, previous listings and sales of the subject property within the past three (3) year period?
- Did the appraiser clearly state all extraordinary assumptions and hypothetical conditions employed within the appraisal?
- Did the appraiser develop an opinion of the highest and best use of the subject?
- If exposure is relevant, did the appraiser develop and report exposure?
- When the Sales comparison approach is necessary, did the appraiser analyze sales data available?
- When the Cost approach is necessary, did the appraiser develop the site value using an appropriate technique? Did the appraiser analyze cost data and correctly apply depreciation?
- When the Income approach is necessary, did the appraiser analyze rental data?
- Did the appraiser reconcile the applicability and relevance of the approaches to value?
- Did the appraiser address prior services within the past 36 months?
- Did the appraiser include a signed certification?” “So, maybe they think they are exempt from an SR3 review?
“State Requirement: Quantity 2 USPAP Standard 3 Compliance reviews per year for each Colorado appraiser (2 for each appraiser per year) on AMC panel with random sampling of original appraisals (AMC Compliance Rule 4 CCR 725-2)”
“17.4 An appraisal management company must have a controlling appraiser, with an active controlling appraiser’s license, to perform services requiring a license. If the controlling appraiser leaves the employment of the appraisal management company, the controlling appraiser or an authorized representative of the appraisal management company must notify the Board within three business days in a manner acceptable to the Board. Upon such notification or discovery by the Board, the license of the appraisal management company will be placed on inactive status unless or until a replacement controlling appraiser has been identified by the appraisal management company and approved by the Board or a temporary controlling appraiser license is timely processed by the Division.” [Read Chapters 17.4 through 17.10] Also read Chapters 18.1-18.3 with particular attention to Chapter 18.1(A).”
NOPE! Not seeing an exception here at all.
Since Colorado requires SR3 compliance, I assume that the “Did the appraiser…” questions also infer the use of the word ‘properly’ in order to be meaningful.
Even if it is a pure yes/no metric, all items except #1, 14 & 15 & (arguably #6) EACH call for an appraiser opinion on the quality and character of another appraiser’s work.
It’s taken me much longer than 10-15 minutes to research factual data for this post or future letter/article. It’s not nearly as complex as a real estate appraisal is.
While I do this out of a desire to protect my profession, the amount of time spent would require a fee of $500-$750 if I were doing this email message analysis for compensation. Fifteen dollars wouldn’t buy the effort required for flatulence.
In searching for ‘AMC Regulatory Compliance Review’, and alternately Colorado RCR, I was shocked to find out how prolific this ‘new’ type of AMC service appears to be.
Clearly it is time for TAF to completely repeal and eliminate SR3 and SR4 requirements on everyone since Major American Corporations engaged in this kind of work think they are exempt from the same standards they are reviewing!
The entirety of USPAP also appears to be beyond the ken of so many state regulators and their licensed AMCs.
GSEs don’t think they need appraisals anymore, & MISMO doesn’t want them.
Real estate appraisals are deemed no more necessary than sub-par ‘evaluations.
Congress doesn’t appear to want FIRREA, Dodd Frank or USPAP enforced so maybe it would be best for all if we dump FIRREA and Dodd Frank.
Make USPAP a purely voluntary standard and save everyone a LOT of money and aggravation. End the pretense of ‘protecting the public trust.’ It’s no longer convenient.
Those of us that follow professional standards will remain at the top. Those that don’t, won’t. But at least then we won’t have know-nothing incompetents with unearned authority wrecking careers and turning good appraisers in for not playing ball.
I’ll go ahead and file a complaint with Colorado over this one. Hopefully readers will pick up the slack in their own states. Additional complaints on this one are welcome!
I wish corporations would include appraisers when their marketing committees set out to deliberately & egregiously violate USPAP.