Jim, you covered many diverse topics in your post. You obviously learned a little about the process but still don’t understand that there are cases where no AMC was (is) involved. AMS or appraisal managed services (semi-automated) may have been used. You are also going after the wrong target (imho) from what was posted.

1. If the appraisal(s) are defective file a state complaint against the appraiser’s license. Most (or at least many) states have a fund where users can be reimbursed for fraud losses.

2. If CFPB has no interest or ability to resolve your case contact the Financial Crimes Enforcement Network of the U.S. Treasury Department (FinCEN).

It should be next to impossible for a reverse mortgage to be underwater. They start out at a 50% limit and beyond that the historic practice has been for lenders to further ‘cut’ the appraised value on reverse mortgages rather than to inflate them. It enhances the yield indirectly by delivering a reduced risk mortgage that instead of being an ostensible 50% LTV, may in practice only be a 30% to 40% LTV.

PAY someone (competent) to review the most recent appraisal used to finance the property for a (cash out) reverse mortgage as of it’s the effective date. Then send that review along with the original report to the state. LET THE REVIEW APPRAISER KNOW it is your intent to send it to the state!

Good luck. None of us support or condone fraudulent loans, appraisals or policies that defraud consumers. Call me if any questions. (714) 366-9404 (AFTER 10 AM California time please). Any day.

Why would a mortgage servicer hide, deny, lie about whom their Appraisal Management Company is? I am a buyer who had the same appraiser hired by the unknow AMC three (3) times in a row within eleven (11) months at the same residential home. A drive by appraisal, walk thru appraisal, and Last & Final Appraisal. There were problems w/all three appraisals with overvaluing by substantial margins & ignoring all necessary repair & restoration. Mold, Lead Paint, FEMA 50% rule & depreciation ignored as well as elevation certificate & re-valuation by the local county appraiser. Even after filing complaint thru the Consumer Financial Protection Bureau the Mortgage Servicer responded by directly lying in writing as to who the AMC was. Champion Mortgage (Nationstar; aka Mr. Cooper) replied back stating the AMC was a company called ResNet. I called ResNet directly and was informed they were a Software Platform handling various different duties, but they do select a list of Appraisers to give to the Mortgage companies but they Never select the appraiser.

It is my belief that the Mortgage Lenders even after the banking collapse in 2009 with all the Overvaluations are still setting and or controlling the valuations of the residential homes. I would like to learn how the AMC’s are brow beating and strong arming the appraisers into raising and or lowering their valuations to meet thresholds of the AMC for the Lender. I’m in way over my head, but learning constantly after pursuing this for almost three (3) years. I have filed multiple complaints w/ the FED & State agencies but other than documenting the facts these agencies give the consumer little to no support.

Troll Alert: This comment/commenter was flagged as suspicious!

TSI now Amrock has changed and they are delusional. I was even told by their Director of Vendor Management named Donna Chabot that they are “black and white” now because they are losing business. She also went on a rant about how they are willing to go through as many appraisers as they want to and don’t care and value partnerships like they used to and their policies have changed and hung up the phone. I looked her up and she use to own her own company and now she has to work for an AMC!? No wonder she couldn’t hack it as a real appraiser…she is a vicious ***profanity redacted***

I think Daniel’s  issue is the degree of analysis or reporting of it. USPAP has no set rule on how far one has to explain after an analysis. The fact he said he knew the sale price; analyzed the contract and that market data did not support it meets the analysis requirement (in this sentence). I’m not exactly known for brevity of explanation but even I stopped trying to fully explain or justify appraising a property below a sale price anymore. It’s not necessary. Its not my job to explain why a buyer offers more than a property is worth. I’m not a mind reader.. The original intent of the requirement is to determine if non market incentives or undisclosed conditions appear to be a part of the deal.

Like so much out of TAF these days, original intention and purpose takes a back seat to some one size fits all presumed rule.

It would have caused plenty of grief if the appraisal was later reviewed by a competent review appraiser and comps in the immediate subdivision were omitted by the OA (especially the recent sale of the house next door) and included by the RA. Is it appropriate to ignore recent sales and listings inside the subjects subdivision and go outside it just to make the deal work? I don’t think so. That’s called “rubber stamping” and that’s inappropriate any way you slice it! Looks to me like the appraiser was 100% in the right. I’ll have to agree with Fred the buyers agent DID NOT have his clients best interest at heart and was only after the commission. I wonder if the buyer even knew that two appraisals were done on this house?

Daniel, real estate agent not the “AMC agent” as you describe it. The AMC made no comment and  did not act as a firewall in this instance but simply collected their fee  and moved on to the next  deal. The conversation was between a Bank of America employee (the AMC’s client who lied by the way) and the buyer’s real estate agent only. The appraisal clearly stated that the contract was analyzed and that the appraiser was unable to justify the contract price utilizing the best sales available. It’s kind of hard not to do that given the layout of the 1004 form. Don’t you think that if there was a USPAP issue, the board would have pointed that out and acted accordingly and not dismissed the complaint? I’m not sure I follow what you mean that the explanation does not have to be correct?

I must be off their preferred list because I always point out that what they are asking is not part of the appraisal process. For example, TSI wants the report to include a “farm list”. I had never heard of that before but they want a list of possible comparable sales in the neighborhood to be included as a one line print out for each property. Never mind that I explained that a property was either a comparable or it was not. In any case, if you return a report that includes a value that they question, you will also get a list of sales (maybe up to 5 or more) and a request to comment on why you did not use the sales that they have cited. Standards Rule 1-4(a) requires “When a sales comparison approach is necessary for credible results, an appraiser must analyze such comparable sales data as are available to indicate a value conclusion.” So, the appraiser must determine what data is relevant. It is not up to the “client” to hint at what sales should be used in a report and it is way beyond the scope of the appraisal to explain why a list of sales were not used. It is not the appraiser’s obligation to explain why each sale was not used. It seems to me that the “client” is cherry picking sales to influence a value. I explained my reasoning and cited several conflicts with USPAP when they ask for other sales to be either used or explained why they were not. Needless to say, I have not been receiving requests for appraisals from TSI in the past 3 years.

https://www.housingwire.com/articles/42556-monday-morning-cup-of-coffee-countrywide-landsafe-accused-of-fraudulent-appraisals-during-housing-boom

Fred we have been trying to get many people to do more than complain futilely. Join us at http://www.appraisersguild.org

Skapinetz – sorry

Soon the only access point will be at assessors, management companies, or commercial side appraisal. Avoid facebook. Your data is on the permanent record, routinely sold, and there is no actual privacy.

100% Real Estate Appraisers on Facebook.  It’s a “secret” group so you may need to search for Mark Sapinetz also for permission to get in.

I’ve heard mostly unpleasant things about AI with the exception of a local appraiser telling me to take their courses. Also, I can’t find the FB group you’re referring to.

They completely forget the biggest thing…… if the trainee does not want to move to an area that actually needs an appraiser, all they are going to do is over supply…….. which is probably what they want. in some areas.. but is that not wasting their time or money ????

Yep. They are on my blacklist too