Thank you Pat. I’m hopeful that FHA will not adopt this new form. Or that once implemented, the ensuing industry wide calamity will illustrate this programs flawed presumptions about form filling. It’s discouraging that FHFA stepped in to the GSE’s and cracked the whip on the long delayed slow roll out of the appraisal modernization campaign. Like get back to work we need results people, without more carefully examining the appraisal industry.

They should scrap the new appraisal forms project all together. If there is additional data required, they can create a one or two page additional form set for appraisers to include instead. Non appraiser tech people whom are not receptive to licensed appraiser criticism or suggestions created the new form. They don’t even grasp the most basic concept that the adjustment grid is a math equation, the necessity of that being on one single page, with clear net/gross adjustment indicators, and other basic elements. None of the rest of the industry will adopt this new form. Not courts, not lawyers, not independent appraisers taking private requests. The new form creates a different standard which will alienate the most qualified and experienced appraisers out there, and be even more difficult for consumers to comprehend or get additional third party opinions regarding.

But again, that appears to be the point. They’ve spent years and millions of dollars, confused everyone, and there has never been a clear direction on this ‘interactive form’. It’s still to this day some tech persons wild dream of something new, and has never been something the appraisal or lender community has agreed upon or the majority having proclaimed is vital and necessary. The top people whom demanded the new form and got this rolling are literally fired and no longer working at these institutions. So why are they continuing to push the new appraisal form? The cumulative brain drain and human energy expenditure needed to implement a highly complex technically challenging new digitally interactive lending form has not been measured. Certainly millions and millions of man hours will be wasted on this through every faucet of the industry; appraisers, software providers, brokers, underwriters, realty agents, consumers, insurers, the new need for ongoing advanced technical support. They’re all going to be completely confused. That is the opposite of efficient process. DOGE the new appraisal form immediately is what most appraisers agree on.
____________

Was re reading posts on this one today. Thank you to the many posters whom chimed in with positive commentary. In other related threads, several posters stated how they actually did call into Morgan and Morgan trying to bring attention to the content on this website. Also how they personally called FHFA and had a difficult time reaching anyone. Those are the efforts that can make a real difference. So thank you everyone whom made that effort. Keep trying. If you did not make it through, try again. Everyone reading this, please take the time to write and call, if all you do is provide a link to several recent articles here, that’s a meaningful action worth the time and effort.

And a final push; FHFA contact information link.
https://www.fhfa.gov/contact

OCC contact link (oversees the ASC and all the orgs downstream of them.)
https://www.occ.treas.gov/about/connect-with-us/contact-the-occ/index-contact-the-occ.html
CongressionalLiaison@occ.treas.gov (via the congressional affairs link.)
https://www.occ.gov/about/connect-with-us/index-connect-with-us.html
https://www.occ.gov/about/connect-with-us/whistleblower-protection/index-whistleblower-reporting.html

I’m impressed that she appears to have actually read my economic theory posts. Hopefully.

I was hoping Vince would keep at it, I’m still not sure what he meant by credit unions being good old American socialism.

Maybe if we slapped an orange toupee on some of the GSE employees and amc trade group people, ran a few news hit pieces, more people would pay attention to this vital issue.

Let’s recount. A person shows up constantly berating appraisers. Specifically intending to dilute or distract from any message which claims the current system with amc’s has deeply rooted fundamental problems. Always showing up to indirectly defend amc process. Then disparages people and uses the classical reverse psychology calling known collusion a conspiracy, while claiming success gained from lack of ethic and predatory behaviors is in fact, the proper avenue to take. Presuming those whom advocate for honest process, are not working and are simply not capable individuals.

Must be the PR arm of the amc industry or something similar. Nobody here is buying this tired rhetoric. Jr, is that all you’ve got? I’m very entertained and sure many others find your antics intriguing as well. You can’t make predatory activity something the masses will accept. You can’t make racketeering legal. And a tiger can’t change it’s stripes. I think it’s pretty obvious who’s on the side of truth and justice, standing up for tens of thousands of small business appraisers and consumers alike, and whom is attempting to provide cover for financial predators.

Thanks for playing. Try again. You may consider something more effective than copying statements and throwing attitude.

Pointing the finger at appraisers for the 2008 crash is like blaming the weatherman for the storm. Were some appraisers swayed by lender pressure? Sure. But the real architects of the disaster were Wall Street’s toxic mortgage-backed securities, regulators napping on the job, and lenders peddling predatory loans. Appraisers didn’t dream up subprime mortgages or package them into trillion-dollar catastrophes—we were just trying to navigate a rigged market.

Let me share a slice of reality from before the crash. I regularly appraised properties below contract price—once, a new construction came in 15% under, and the builder tried to blacklist me. Buyers still paid full price, coughing up extra cash to bridge the gap in a seller’s market. I checked those properties years later: every single one foreclosed. So, who’s to blame? The appraiser who called it accurately, or the borrowers and lenders who ignored the red flags? I wasn’t alone—colleagues reported the same. We held the line, but the market’s frenzy steamrolled reason.

Your idea that AMCs fixed lender influence doesn’t hold up when you look at cases like Fastapp AMC (https://appraisersblogs.com/alleged-violations-of-appraiser-independence-at-fastapp-amc), where Horowitz, the AMC founder, directed “thousands of appraisals to a small handful of appraisers who will appraise properties at values requested by Horowitz’s broker and lender clients…” That’s not independence—it’s a quid pro quo, and plenty of evidence shows AMCs pressuring appraisers to hit numbers.

Technology’s here, and fees shift—point taken. But waving H.G. Wells to call appraisers dinosaurs dodges the real issue. We’re not anti-progress; we’re sounding the alarm, like the article does, against hybrids, AVMs, and REO fire sales that risk another bubble. If you’re doing fine, congrats. But writing off struggling appraisers as lazy while ignoring AMCs’ predatory practices and FNMA’s loan shell games is a flimsy cop-out.

” Only deficient appraisers whom can’t make a living, turn to exploitative amc models. Meaning the other three out of four appraisers whom service legal, courts, government, private, and the best lenders in the business whom did not take the amc route, they’re the deficient appraisers. It’s the cut rate outsourcing automated amc appraisers whom are the best. How could anyone have missed this? We’ve been wrong all along!

Where in the heck did this guy come from? Obviously pro centralization pro amc. We’re all hiding in the shadows now, hoping to not have our deficient services ‘discovered’. Jr, you can’t be serious and if you are, quite unserious and not worth listening to. Great story telling though. File that away in the fiction section, perhaps even some form of amc propaganda.”

Saying appraisers who (well you incorrectly say whom) do work for AMCs are deficient appraisers who can’t make a living otherwise, is the most egregiously foolish statement I have seen here. Its flat out ignorant and insulting. As I’ve said before, there are AMCs who pay as much as direct lenders. You have to find them. And if you aren’t smart enough to do that you are leaving money on the table. Just like you need to be smart enough not to work for the bad ones. Most appraisers I know have a mix of work from numerous sources, banks, mortgage lenders, AMCs, builders, CUs etc, and are very busy. Its easy to tell the appraisers who can’t hold a client. They are the ones wanting “a round robin” and no checks and balances on their quality or service.

I’ll await more of your conspiracy theories as to why you can’t get work, why everyone is out to get you and why AMCs owe you billions. Its entertaining.

Professional complainers. You are prolific if nothing else.

Nope. Wrong again. Many of the mb’s and appraisers whom were partaking in the inflated highest and best over valuation game were washed out fired or both. Entire institutions and people whom worked for them were gone before amc’s ever gained dominance.

Stop whining about appraisers whom stand up for their careers, casting a blanket and projecting your own insecurities regarding a valid secondary check and balance system. As if all the products on the market at the time, which failed miserably, were somehow approved or put in place by the appraisers. You may be mistaking the fault of the melt down with appraisers, while the blame lies much further up the ladder. If not for appraisers signaling the alarms at the time, the harm would have been much worse. You do not know what you’re talking about. Only deficient appraisers whom can’t make a living, turn to exploitative amc models. Meaning the other three out of four appraisers whom service legal, courts, government, private, and the best lenders in the business whom did not take the amc route, they’re the deficient appraisers. It’s the cut rate outsourcing automated amc appraisers whom are the best. How could anyone have missed this? We’ve been wrong all along!

Where in the heck did this guy come from? Obviously pro centralization pro amc. We’re all hiding in the shadows now, hoping to not have our deficient services ‘discovered’. Jr, you can’t be serious and if you are, quite unserious and not worth listening to. Great story telling though. File that away in the fiction section, perhaps even some form of amc propaganda.

Thanks for playing. Try again.

How essential were the appraisers in the 2008 crash, the largest in our history? I’ll give you a hint while you are touting our irreplaceable importance to consumer protection, we were right at the foundation of the housing crisis. Negative Ams, buydowns, Builder points in excess of 15% skyrocketing appreciation. Yep, they appraised just fine. Lender influence wouldn’t have been a big deal if appraisers didn’t succumb to it. The housing market collapsed with you at the helm. Sunk like the Titanic. Now you are screaming that you are the only thing keeping the housing industry from ruin?

AMCs were few and far between back then and their explosion came out of the need to interject someone between the lenders and the appraisers to stop the influence. We’ve made this bed, now we are wetting it whining that our business stinks because of an AMC, a hybrid appraisal, or disposition of REO properties. Its a tired cry. Honestly in my area the appraisers who are starving are the ones who have given terrible service, acted entitled and more important in their roles than they really are through their existence. They are running out of places to hide. This is all just a new excuse to be a starving appraiser.

The market is changing. Technology is here. Fees aren’t staying as high as they were. Appraisal requirements and forms aren’t static.

“Adapt or perish, now as ever, is nature’s inexorable imperative”.

H. G. Wells

It is precisely why GSE’s keep scope creep and adding more and more data points, data analysis, new forms, 1004MC is in… then 1004MC is out… and all sorts of requirements. They truly believe that they have pushed appraisers out with “modernization” while appraisers continue to adapt… and very well at that.

You want modernization? Get rid of ENV files, get rid of AMC’s that clog up the pipelines and reduce revenue for the ones actually doing the work (and prevent the use of trainees, etc) which in turn would allow appraisers to hire and train a whole new generation.

The only appraiser shortage has been purposefully caused by GSE requirements, AMC’s intrusion and monopoly, and DEI in order to create the environment for their mass AI driven appraiser-less valuations against all sorts of Federal and State laws, ethics, morals, and intelligence.

Talking about an end to never ending war, an end to foreign interventionist policies, sound money, oversight of politicians and bureaucrats. Evil partners in crime the dastardly villains Daniel McAdams and Chris Rossinni, Senator Rand Paul, Congress person Thomas Massie. Their financial facilitators; Birch Gold group and citizen donations. The yearly meetings for the Liberty Institute with all the thousands of guests and keynote speakers.

https://www.youtube.com/ronpaullibertyreport
328,000 subscribers, on one site alone. Clearly, all you have to do is sit through one episode, the proof is undeniable.

Try something new.
https://thefederalist.com/2021/02/23/stop-smearing-christians-as-christian-nationalists-just-because-they-value-both-faith-and-freedom/

This person needs the knowledge of appraisers whom can post the relevant state federal and applicable gse guidelines, the over all structure of the portion of the industry, to help her legal staff determine the appropriate course of action. FYI, matters pertaining to ITBS reports and loan approval are the lenders responsibility. All the appraiser does is report ‘eyes on site’ data to the lender, per the appraisal performance guidelines prescribed by the GSE program, the lenders underwriting guidelines, state licensing requirements. After that point, compliance requirement is the full responsibility of the lender.

There used to be a follow up requirement for the independent third party appraiser to provide a follow up ‘final inspection’ report to verify any ‘subject to’ appraisal requirements were met. Inspectors safety verification, completion or correction of property deficiency, missing fire alarms, failure of basic utility function tests, missing tags, etc, etc. This is but one of the now effectively retired work products appraisers no longer are able to as regularly tap into. Issuing final inspection requests brings alongside the likely probability of that appraiser being substituted via down grading or down ranking, having a longer over all turn time and higher fee, substituted for appraisers whom do not call such important third party verification or compliance assurance. Again, for labels and tags, that data must be stated on the Manufactured Home appraisal form, but can be over ridden by the underwriter if the appraiser reports the data is not available and stickers or tags were removed.

“In fact the only person whom stepped up was the appraiser.” / In most probable scenarios; that’s another appraiser sidelined and down, limited black listing. If the lender is tied into an amc, that appraiser may have been put on a multiple non VA lender blacklist as well, via tiered performance and volume ranking downgrade.

Rose. Use the ‘contact us’ link at the top of the page, contact the site administrator, and see if they can put you in touch with an appraiser in a more private manner for more detailed accurate information.

Your story sounds very familiar.

https://appraisersblogs.com/uncovering-flaws-in-fha-appraisal-n-loan-review-process/

Comments and advice will be appreciated. Freddie and Fannie have rules and guidelines but what does it matter if rules are simply ignored?

It is exhausting trying to address mortgage fraud and lender altering of documentation once the fraudulent paper trail was discovered. In our issue of appraisal failure and that the seller (Freddie) property being ineligibile in the first place (but ignored to pass the seller-servicer failed eligibility buck onto the VA buyer), we found no accountability by lender, Servicer or VA. In fact, the only one who stepped up was the appraiser. The VA has admitted part of the problem is lack of lender SAR oversight, and that our specific type of lender fraud utilizing counterfeit and incomplete documentation is new to them, and they don’t know how to force the lender to address and remedy. Lender does not care as they just want to steal our property– knowing the vacant land is valuable even if the fraudulent manufactured home structure must be removed. The whole situation was begun with a mh dealer taking a decertified, for salvage my and using fraudulent documents called it new to the county record. The appraiser failed to stop work and require lender obtain IBTS Verification when no HUD Labels were found on the structure. The lender ignored duty to order IBTS and just passed everything as if true and complete. The discovery and confirmation of the waterfall of fraudulent paper trail has become a nightmare. Every professional involved points to another and my disabled veteran husband and I are left holding the empty equity bag.

The raw materials argument is a reality of modern civilization. Why economists examine this over and over again through the centuries. Governments tend to not be very good at creating wealth, or managing wealth, but rather focus on redistributing other peoples wealth, often in wildly disproportionate unfair manners. Taxation without representation has become the new status quo. So yes, a reductionist theory may be a more realistic way to look at things. That does not mean we’re asking for socialism, but rather taking a more realistic pragmatic approach to problem identification and problem solutions. Article 1 Section X, no thing but gold and silver coin…. We’ve been living on borrowed time this entire time. Illusionary wealth, from the printing press.

When people talk about firing up the economic engines again in this country, they are really talking about the need for raw materials, production, harvesting, labor, etc. When they turn to government incentives and attracting capital as a trade off to investors from half a world away, they’re not gaining wealth for the people, rather engaged in a series of trades which often involve imbalanced wealth distribution.

Everything downstream of raw material production on the supply chain is just trading wealth. Which is why fiat currency and fractional reserve banking is so frightening. Wealth created out of thin air is merely a tax on the money and it is not wealth creation. Which is why we say; we’re tired of the inflationary policies.

The government incentives to direct more into housing or any system than the people and the free market can sustain, is what leads to the market bubbles and eventual inevitable collapses. The poisonous protectionism is made possible by…. You guessed it; central planning.

On the question of regulation. That’s more complicated. We expect our money to be safe. And people place their wealth into lending institutions, anticipating a positive outcome. Then when things go wrong, the banks lawyer up and protect their ill gotten gains. So the people call for government to help. Then government gets involved. Then government becomes co opted by those seeking ill gotten gains. Then the money is not safe, all over again. Now the wealth is increasingly consolidated through centrally planned systems, at even greater risk than before the government ever became involved. And all losses get charged to the taxpayer instead of the losses being borne by the one institution, and their customers. So now everyone is taxed, instead of those whom took that risk to bank with banksters whom were taking all those risks.

That is taxation without representation, the point of the argument. Sure go ahead and regulate the hell out of the lending institutions if that’s what needed for general economic stability, but we should not have the taxpayer backing and deposit guarantees. It’s all an illusion anyways, FDIC could not cover a fraction of a fraction of a single percentage of deposits, the unfunded liabilities are already that far out. That’s where tort law is supposed to come in for end of the line accountability. And that can’t happen properly when the government by way of the back stop, is also providing liability shields. That’s how we end up with the Holder Doctrine and too big to fail.

My vote remains for; fines based on income for corporate and large businesses. Then when companies and bad actors take those risks, they won’t be able to sit back and count all the cash later, even when things go wrong. One of the most devious things about inflation, is that table based fines can never keep up. Therefore the wrong doers are always ahead of the regulation and penalties. If the penalties actually served their intended purpose of dissuading the behavior, the companies would go insolvent, their companies will be auctioned off, and the next entrepreneur is unlikely to follow the same pattern or mistake. Instead of what we have now is a finely tuned machine where they all know how to exploit the system, and exploit the system they do. If you’re a regular guy and break the law, lie, cheat, steal, you go bankrupt and lose everything, then you go to jail. But if you’re a corporation working with the government, embezzle fraud cook the books, like cheat and steal on top, no big deal, tax the loss and keep moving. Continued profits.

I think a few hundred years ago, someone talked about this. Image attached. ‘Bank wars’.

Beyond the unnecessary complexity of the form, the grid being spread out over multiple pages which creates mystifyingly difficult mathematical reconciliation, no combined net/gross adjustment indicators, down to irrelevant matter which is clearly using appraisers to become superfluous data gathering minions for later monetization and privacy violating aspects of consumers data. To the inability to print out the form on paper for ease of explanation to home owners or to work in challenging situations where the full array of fancy and unnecessary tech items may not be present, or charged. We need something we can print on paper before the form begins to be filled. New forms are like a great reset, stun everyone for no apparent reason, turn everyones lights off, trash a century of meaningful appraisal form development to start from scratch, then call it modernization. It would appear the appraisal modernization program has this entire time been one big setup to install a different system which functions more as a liability secrecy shield, a fraud facilitation tool.

Nobody outside of the GSE realm will understand the new ‘interactive’ form. Not the state board members. Not the independent appraisers whom may be called for third party review or comparative second opinion appraisers whom use general purpose forms or are only familiar with the 1004. Not the lawyers, not the judges, not the juries. Not people reviewing comparative general purpose or traditional 1004 forms. Not the underwriters, nor the administrative non licensed appraiser reviewers. FNMA’s new forms virtually guarantee that meaningful appraisal review outside of gse specialty appraisers can not happen, or if it does, it will be many long years before everyone can get retrained up to speed. So only compliant amc appraisers will fill out the new forms, and be able to review those forms. Mandating a rubber stamp on everything. Appraisers will be powerless to answer conflicting contradictions, as the interactive form suddenly adds this one thing, and takes this one thing away simultaneously. There will be no fixed standard anymore.

FHFA stepped in and said; get everything back on track, no more delays. They moved up and clarified the timelines on the new forms, probably whipped the developers around a bit. But they’re stepping on a landmine with the appraisal modernization campaign, doing the dirty work without realizing what’s happening.

FHFA should scrap the new forms project and be done with it right now asap. That’s called cost savings and eliminating unnecessary redundancies. If there is new or more data that FNMA wants, they can simply draw up a one page new form with new data points to fill and say this additional form will now be a required add on to the 1004 form for all origination transactions.

See how easy that was? I could draw that up myself using simple tools in a week or two, and fit all the new data lines they want in there. Block it out. Add a few interactive data mapping points to several data fields. Done. This should not take an entire team of technology graduates three years and millions of dollars to produce. They made the new forms unnecessarily complicated, as is typical for tech people these days to milk their positions by screwing everyone else over whom does not know how to code. FNMA could have sourced free labor from gaming forums and gotten this project done quicker and more comprehensively than what they’ve done. The new forms development committee has consistently downplayed or ignored never ending appraiser objections and criticisms at their meetings, and through written communications.

We’re all thankful the new forms have been delayed this long, and are unlikely to be adopted by HUD or the VA. Nobody is polling appraisers on these matters. Ask a thousand appraisers if they want to use the new forms, from what we can gather online, most say absolutely not. Three out of four appraisers nationally refuse to work with amc’s, and amc’s dominate over 85% of all origination appraisal requests. Over half of all appraisers refuse to be in service to GSE’s and the mortgage lending consumer for origination purposes, because of FNMA & FHFA policies surrounding appraisers. We’ve got over half of the industry retiring or leaving, and for those that stay, only a minuscule proportion of them will be interested in completing these new forms.

Then FNMA will claim once more; appraiser shortage. And use this as justification to bypass even more checks and balances, move to more automation. They’ll probably say they have an underwriter shortage for people qualified to deal with the new forms. The work arounds are endless and it’s difficult to understand how the appraisal modernization campaign is anything other than a concerted effort to remove the oversight brought by independent third party appraisers. They’re not modernizing anything and should more appropriately brand the campaign as the appraiser elimination effort. And that’s exactly what Mr Miller reported about on the ‘rumor mill’ article. Where he claimed FNMA executives were overheard saying they planned to eliminate the majority of gse appraisers by mid this year.

https://appraisersblogs.com/gse-executive-boasts-scheme-2-slash-appraiser-numbers/

Thanks for your comment. I did see in the 4am news today that FNMA was somewhat exposed in regard to the condominium “blacklist” in Florida. I though that was interesting. I’m not sure if the media is afraid to mention indiscretions or they just aren’t getting the information. Likely, a little of both.