Tagged: USPAP

Existing Regulatory Burden on Appraisal, a Proven Failure- System Reform 6

Appraisal Reform or System Reform

It is my hope that the Subcommittee on Housing, Community Development and Insurance consider long-term impact. The existing regulatory burden, a proven failure, may insure a repeat of the past. The body of a letter to the U.S. House Committee on Financial Services about systems reform. Appraisal reform or Appraisal industry reform? It is critical to understand that ‘appraisal’ does not equal ‘valuation’, or risk analysis, or anything else.  It is a precise definition of a nebulous product. The current U.S. House Committee on Financial Services is asking the question: “What’s Your Home Worth? A Review of the Appraisal Industry.” I believe it is...

North Dakota Appraisal Waiver Granted 8

North Dakota Appraisal Waiver Granted

News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...

Coester Risen from Ashes? - Homeowners to Provide Data for Evaluation 26

Coester Risen from Ashes?

Has Coester risen from the ashes? Apparently, per a message on Twitter on July 9, 2019, Mr. Brian Coester is now in the real estate sales biz. The photo image used on the big T is the same one he used to use on his defunct AMC website. More information here for re-posts of articles not written by him. Meanwhile, there appears to be a new twist in Evaluation appraisals. This is the first I’ve seen about an AMC or any other company using ‘the homeowner’ to supply interior photos which will be used in a bank evaluation. See this...

Review Appraiser Flawed Review... Phony Complaint Against Appraiser 14

Phony Complaint Against Appraiser

…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...

Complain About a Complaint Filed - Who Can Complain About Appraisals 71

Who Can Complain About Appraisals?

Time to get on my soapbox and complain about a complaint filed against me (not a charge, but merely a complaint). I did an appraisal of a multi-family property near my office. The property owner/borrower called me to complain about the appraisal since it came in far less than she thought it should (not unusual). Clearly, I could not answer her questions since she was not the client. This upset her greatly, so she filed a complaint with the State. The complaint had no basis in substance. In fact, the complaint was that my appraisal was too low. Since neither...

Clear Capital Admitting Hybrid Inspectors Are Offering Appraisal Opinions 34

Hybrid Inspectors Offering Appraisal Opinions

Clear Capital admission: This is an admission that inspector were previously offering appraisal opinions re Q&C. There remain many other areas in hybrids that also are appraisal opinion being provided by non appraisers. I have written many blog posts here, mainly for the consumer to read and understand what is actually happening in the world of Real Estate Valuations. My blogs range from being overcharged for appraisals so the middle man (the appraisal management company or AMC) can make money, lenders still pressuring appraisers to hit a value, and now having untrained and unlicensed people perform inspections (see my last...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. http://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Bifurcated Appraisals, a Controversial Topic - Call to Action! 5

Bifurcated Appraisals, a Controversial Topic

As most of you know, hybrid or bifurcated appraisals are a very controversial topic currently. Virginia statutes and regulations have language which gives many of us pause on the compliance of hybrid appraisals as they are being presented in the industry. The Board has published a proposed guidance document in the hopes to clarify the language in our laws. Unfortunately, the proposed guidance document falls short of providing any meaningful guidance or clarification. Per Virginia statute, the document has been published on Virginia Legislative Town Hall for public comments. At the end of the comment period, it is our understanding...

Different Properties on the Same Form? Are you Appraising the Bulk... 11

Different Properties on the Same Form?

Are you appraising the retail values of 10 sites to 10 different owners? Are you appraising the bulk or discounted market value of the 10 sites to a single purchaser? Can the Same Form Have More Than One Property on it? Lots of folks have asked me, “Dustin, can I appraise two different properties on the same appraisal report at the same time?”. Now understand I am not a USPAP instructor, I am an appraiser, so I’m going to answer this question as best I can. The question before us is legitimate, and one which I had to answer recently....

Score Card, Turn Times, Undue Pressure & Appraisal Independence 16

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...

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