Protect Appraisal Report Integrity

Protect Appraisal Report Integrity By Delivering Locked PDFsObviously, it is easy to unlock a pdf report, but we lock every report as an effort to maintain report integrity. This should be a regulatory requirement. Periodically we have seen reports we delivered electronically that ended up being modified to the client’s needs.

This almost happened a week ago.

My firm received this request from Servicelink on a BoA request. In accordance with the new AMC law in New York State, we are including the invoice with our reports. This was the first report to this particular BOA group since the new law was activated so it is reasonable to assume that the BOA clerk handling the appraisal didn’t know what to do about the invoice and Servicelink was passing along the request. The law itself says the invoice must be delivered with the report which infers but doesn’t specifically state that the invoice should be within the report pdf. I would imagine there will be a lot of attempts by lenders to get rid of invoices out of habit but after a while, once appraisers start seeing invoices missing from the applicant copy when an applicant calls the appraiser, the appraiser needs to complain to the CFPB. I remain skeptical that lenders will be able to sustain a systemic fraud or ignorance to the spirit of the NY AMC law by hiding the invoices from the applicant and risk doing future business in one of the largest mortgage markets in the U.S.

Our client, Bank of America, has accepted both appraisal reports. Unfortunately, they are having issues uploading the documents into their system due to them being locked and password protected. Are you able to modify the permissions to allow printing and unlock the document? Please let me know as soon as possible so we can deliver to the client.

Red flag: How could they have accepted the report but never uploaded it?

I personally tested the pdf they sent back to us as well as our original copy. They both printed as usual so we told them they must have a software issue on their end. We have never had to deliver unlocked reports to this client and as practice. It is ALWAYS inappropriate for an AMC to request an unlocked report. There is only a nefarious reason behind it, even if the requestor themselves have no idea.

Causation, not correlation: The first time we get a request to unlock = first time we attached an invoice.

Here is how we respond to these things:

Thank you so much for the business. We greatly appreciate it!

Miller Samuel does not unlock pdf’s or remove passwords. So we just can’t help in this situation. This is done to protect the integrity of our report as a matter of policy with every client.

Thanks again and we look forward to working with you in the future!

Here’s what Servicelink told us after we said “no.”

We were just looking for a partnership here to try and meet the needs of what is a very important client to ServiceLink.

Until the new New York State AMC Law is fully adopted by the AMC industry, expect to get these requests. Part of the issue is software updates or internal procedural changes and part of it – like this example – is nefarious.

Jonathan Miller
Image credit flickr - Christoph Scholz
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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11 Responses

  1. Baggins Baggins says:

    One may speculate what appraisers would find if we were allowed access to the CU database to review at least all of our own report submissions for congruency and integrity of the data. Locked files may complicate the processes involved with automatic report submission software which seeks to data mine a certain portion of all reports for indexing, filing, and other purposes.

  2. Great looking out Jonathan.

    I hope ALL appraisers know that the xml and env formats were specifically created to enable the client to report ONLY those portions of an appraisal they want, and in a new or revised format ‘convenient’ to their client.

    I want to know how THAT particular practice was ever started or allowed to remain unchallenged. Didn’t USPAP always require us to take positive steps to assure our reports would not be misused to mislead?

    You & I and virtually every real appraiser complete form reports in a uniform manner to assure the client and intended users receive ALL the information necessary to make an informed decision consistent with the purpose and intended use identified in the appraisal report.

    NO ONE should have the ability or right to alter that in any way. No one.

    Interesting aside along these lines. Those proprietary ‘bifurcated’ avms filled online ALL have the ability to be revised and manipulated…which is why their hucksters also require your signature file. Yet another reason none of us should ever do them (client proprietary non fnma that is).

    • Avatar Koma says:

      Yes Mike and you know what they say; Don’t worry because and copy of your PDF is always attached to the converted report. Didn’t we hear something similar to that after the crash when they bundled mortgages and most of the doc’s with those mortgages were not together, lost or something to that effect?

      • Right. Those would be the same trusted document librarians that didn’t even have signed documents in the file so they could foreclose? Hence robo signing later.

        I’m SURE we can count on them to keep the paperwork straight, honest and above board, right? You know. Like they do during the appraisal process when then send us fully executed contracts to review.

        • Baggins Baggins says:

          “We were told to sign blank pages, and that’s what we did. It was our job.” keywords; robo signing, mers, clouded title.

          Flash forward 2019; Just don’t lock the file, we need to process this using our proprietary systems and the tech guys don’t like locked files anymore.

          The author of the article is dealing with typical tech focused companies ineptitude. These supposedly advanced appraisal management systems have always been a gimmick. Ask the clerks to do something new and nobody knows what to do, they are bound to the existing programming limitations. The software has been in place as a profit and control tool for a while but the guys capable of re-coding the software are long gone or on to bigger more important projects. Gotta feel bad for the process clerk who just keeps getting an upload failure error, has no resources on their side to handle it, and desperately tries to lean on the appraiser instead.

  3. Avatar Koma says:

    Jonathan, Good catch and thanks for sharing.

    Not that this is the same but, similar to AMC Stewart Lending Services wanting to have your report digital signature on file in order to complete work for them. In my opinon there is no reason in them being able to unlock your report nor having your digital signature on file.

    • Baggins Baggins says:

      Only 10 years later, we’re back into the signature sharing argument? FNMA issued guidance on that previously, or I seem to recall that happening.

      Are you guys locking XML files?

      (attachment is from 2009 IL newsletter guidance.)

  4. Avatar E J Brown says:

    The 1st mistake is doing Any work for SteetLinks to begin with.

  5. Avatar SB says:

    Someone needs to ‘modify” the appraisal of UBER. Zero profits yet the company is worth billions???? DOWN 10% TODAY alone. WTF???

    US Government clamps down on real estate appraisers with senseless regulations while the stock market PONZI scheme thrives for a decade…..

    its pure and total bullshit.

  6. Avatar John Marshall says:

    I always state my fee within the report so the reader knows what I have been paid. Do not need to place an invoice in the report.


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Protect Appraisal Report Integrity

by Jonathan Miller time to read: 2 min