Appraisal Independence

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Score Card, Turn Times, Undue Pressure & Appraisal Independence

Most appraisers could care less about an amc score card… Professionals don’t treat other professionals like they are in grade school…

What exactly is appraisal independence?

Dodd Frank requires appraisal independence and associates it with pressure against the value of the property. But what about other areas of the appraisal process in which appraisers receive pressure?

Let’s take turn times for example. Normal turn times in a steady market average 5-7 business days in most markets. Market activity, location, complexity, etc. will require longer turn times. First let’s define a business day. This is Monday through Friday and excludes Federal Holidays. A business day is not Saturday or Sunday and it should NEVER be counted towards turn times. Some AMCs include them, but I will get to that in a minute.

AMCs want to automate every process. Perhaps that is the case because they do not understand the appraisal process, nor do they trust their employees to utilize intellectual thinking on their own.

“It must fit the box no matter what”

In this automation, amcs track turn times and the appraiser is scored against their peers. Here is a snap shot of an appraiser score card.

AMC appraiser score card

The peer top performer is 5.9 days, but the amc only allows 4 days. The AMC is expecting some sort of “magical miracle” here. Is that not pressure? Does not allowing adequate time to complete an assignment go against appraisal independence?

Here is another example.

AMC appraiser score card

The peer top performer is 7.0 days and the appraiser is right there with him or her at 7.2 days. Yet the amc still only allows 4.0 days. Does this make sense to anyone?

What happens if the borrower holds up the appraisal due to their work schedule? What about the agent who states we need to resolve the home inspection issues before an appraisal can be done. Some amcs hold the appraiser responsible for delays that are simply out of their control. Again more pressure.

What about the absurdity a report must be completed in 48 hours after inspection? What if the appraiser inspects on Friday afternoon? How is the appraiser to verify the data? No courthouse I am aware of is open on non- business days of Saturday or Sunday. No attorney is in their office either. Good luck getting the information you need from an agent who is out showing houses on Saturdays and Sundays. Is this not undue pressure?

Now take bifurcated appraisals. An unlicensed individual performs the inspection, provides some factual data, but also gives an opinion on the condition, quality or utility. The conduct section of the Ethics rule of USPAP states an appraiser:

must not accept an assignment that includes the reporting of predetermined opinions and conclusions ( line 193)

I can only  assume, when this was written  the authors were thinking about values. But does it state values, NO, it states opinions and conclusions. No one could have foreseen that bifurcation would be even an option in the appraisal profession today. Isn’t that exactly one of the reasons FIRREA was passed? Is appraisal independence an issue here?

What if the appraiser does not agree with the opinions of the inspector? Can you imagine how this will play out? More pressure anyone?

Now for some reality.

…appraisers could care less about an amc score card…Appraisers are licensed professionals. They have years of training and experience prior to becoming licensed. Most appraisers could care less about an amc score card. Why would they? AMCs, although required to be licensed in most states are not well educated, nor are they experienced in the appraisal profession. Sadly, they have no clue about anything related to real estate, the mortgage market or the appraisal profession. They are nothing more than puppets on a string. Professionals don’t treat other professionals like they are in grade school. They simply do not! Despite what the amcs claim, appraisers and amcs are not partners!

Who is to blame?

REVAA, the AMC advocacy group is too busy playing Tiddley Winks to care about anything but collecting outrageous dues for whatever benefit they think they provide. You see, REVAA could have been educating their members on good ethical business practices and why it was important for the AMCs to build strong mutually beneficial relationships with appraisers, but they chose to help destroy the profession with no foresight to understand they were destroying the AMCs and themselves in the process. Of course if you have ever listened to anyone associated with REVAA speak before a Legislative hearing, you would understand their ignorance.

REVAA missed another opportunity to educate the AMCs. They could have educated them on the difference between an independent contractor and an employee.  You see when an amc counts Saturday and Sunday in turn times, they have just crossed the line with classifying an appraiser from an independent contractor to employee. Federal and state employment laws mandate how many hours employees work. If the amc requires Saturday and Sunday work hours, most appraisers would be entitled to overtime pay for exceeding 40 hours. There have been several court cases against amcs already over this, none in which the amc prevailed. Has REVAA advised or educated any amc?

Now for the Bifurcation garbage that is being promoted, AMCs and REVAA are once again short sighted. You see Appraisal Management Companies are just that, Appraisal Managers. When someone other than an appraiser is placed into the mix, the amc, in most states is prohibited from contracting with anyone other than licensed appraisers. Has REVAA or any amc stepped up and advocated for maintaining the appraiser in the field? I don’t think so. Instead, REVAA representatives have been promoting bifurcation, completely clueless they are cutting their members and other amcs off at the knees. You could translate this another way as well

No AMC = No REVAA

By the way, enough of these bifurcated appraisals are coming into the hands of licensing boards now. Trust me when I say they will be scrutinized to the nth degree. It will not be pretty for anyone involved.

A Final thought:

Thank you REVAA helping eliminate amcs!  Continue on with your Tiddley Winks games. Licensed Appraiser Professionals will be here to clean up the damage you and your AMCs are creating.

By Advocate, Certified Real Estate Appraiser – author requested to remain anonymous

Image credit flickr - Kelly Teague

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16 Responses

  1. Kimberly Pugh DeFilippis on Facebook Kimberly Pugh DeFilippis on Facebook says:

    AMEN

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  2. David Samnick on Facebook David Samnick on Facebook says:

    Why is the author anonymous?

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  3. Wyatt Powell on Facebook Wyatt Powell on Facebook says:

    Always confused when someone throws out the laugh emoji. Are they laughing at the article? The absurdity? Fat fingers like me?

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  4. Kathy Hubbard Bright on Facebook Kathy Hubbard Bright on Facebook says:

    Good article. Let the AMCs self-destruct. Maybe we will finally be paid at market rate.

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  5. Becky Lowell on Facebook Becky Lowell on Facebook says:

    Yes, we are not “partners” … many good points; I think the author should include their name smile

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    • Baggins Baggins says:

      I checked some old articles, you were commenting back then. Did you miss this one? What’s in your private email? Did I ever tell you about the time I discovered a data logger in my pc which was dropped there by an amc logo w/ malicious code built in? That amc is still busy to this very day. I don’t work with them but there is a possibility you may be… Access to private data is more than just I have nothing to hide, it’s about leverage, insider information, and violations of standard business ethics regarding trust and confidentiality of data. If a company ignores one rule, what stops them from ignoring others? Be careful out there.

      http://appraisersblogs.com/skapinetz-vs-brian-coester-vms-amc

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  6. Angela Meyer Benoit Angela Meyer Benoit says:

    AMEN!

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  7. Avatar Timothy S Evans says:

    There is a flaw in the article, “REVAA” and “ethical” were used in the same sentence.

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  8. Guest – Great article.

    Let’s ALL pay attention to who exactly is promoting the hybrid garbage.

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  9. Baggins Baggins says:

    Tavma, revaa, the same, just a different name. They had to rebrand because the original amc trade group branding, tavma, already had it’s name dragged through the mud thoroughly.

    The old amc playbook is out the window.
    http://www.workingre.com/wp-content/uploads/2013/08/tavma-standards-of-good-practice.pdf

    My favorite now abandoned mantra; Educate clients that fees for services are based on intended use and users and the complexity of the property, and not on an appraisal form type. Among other abandoned revelations’ of the amc industry.

    Nar, still a paper tiger. They never really did anything and still only pay lip service to the issue.
    http://appraisalinsight.blogs.realtor.org/2011/08/12/nar-calls-for-ban-on-amc-indemnification-clauses/

    When the solution causes more harm than good, and still does. On amc’s and out of area appraisers.
    https://therealdeal.com/issues_articles/low-appraisals-sabotage-more-deals/

    Marsh Bilby had a great plan of action. And lookie here 10 years later, turns out title companies were behind so much of it. Too bad nobody listened to this guy.
    https://appraisalsoapbox.com/tag/tavma/

    Interesting how the insurers and publishers flipped the coin and these days seem to advocate against the appraiser. What a contrast only 10 years ago compared to now. It’s true, if people are oppressed long enough, they get used to it and stop resisting. That and who can resist that alluring advertisement money! Certainly not working re, they got to have those ad dollars and they don’t care who gets hurt in the process. Things used to be different though, we used to have hope this racketeering would be busted up in its early phases. The ancillary companies in the appraisal industry used to side with truly independent appraisers, not the amc appraiser hucksters.
    http://appraisertalkback.com/2010/02/02/hvcc-appraiser-last-laugh/

    I could go on, but you also have access to google and can simply tag any modern issue with the word “tavma” to see similar content for yourself, observing the obvious narrative changes and obvious ongoing problems. Use ” ” in order to force the word as a mandatory in the search result. Nothing this industry is dealing with is new. It’s only the clever name and word rebranding that causes the issue to appear new. The amc fraud has been ongoing.

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    • You’ve outdone yourself Baggs! There was never any doubt HVCC was a Big Title Co effort…along with everything that followed. I remember the old rumors about Cuomo clients being big in title Insurance…and oddly something about the octopus tentacles reaching to Sacramento. I forgot the details of that one.

      Every reader here should save these links. I certainly intend too. Gracias!

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      • Baggins Baggins says:

        Thank you. I had simply googled something like this: “Tavma” cost plus article. Hits included so many of the familiar appraisal news stops I frequented a decade ago! A trip down memory lane but it’s like living in the twilight zone. Same old issues, same old players, same old problems. There were so many critical arguments from 2008 time frame. That was before so many senior appraisal pros were forced out of mortgage lending and adopted this just diversify and turn a blind eye to the fraud the other half has to deal with mentality. At first, everyone fought back against amc imposition.

        Just tried “tavma” cost plus white paper. Think I found it.

        https://appraisalnewsonline.typepad.com/files/the-amc-full-fee-hypothesis—jeff-schurman.pdf

        There is so much damning evidence against the current amc model there, I don’t even know what to copy and quote to the board, I’d have to copy the entire damned article practically. The amc industry has flip flopped like a political pro. Where is Schurman now?

        Forget those other links. Read about what could have been to really discover how far away the amc industry has moved from its original promises.

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Appraisal Independence

by Guest Author time to read: 4 min