Reconsideration of Value Requests

Reconsideration of Value Requests & Undue Influence on AppraisersOpen invitation for spurious reconsideration requests…

No thank you.

I just checked your website and glanced at your “clients” tab, Reconsideration request form. It pretty well negates all the puffed up hyperbole in your email invitation.

It is people like you that are the problem, not solutions. Do you think a one of two items drop down menu is an adequate reason for asking an appraiser to reconsider their value? Do you not see a need to request a full and thorough explanation as to why your clients might be asking for a reconsideration? At a minimum didn’t you feel it necessary to offer some specific guidelines and cautions to clients not to engage in undue influence during the development of appraisals?

East2West AMC Reconsideration of Value Reasons

Do your clients even understand what a material defect is? Do they know the difference between relevant comparable (competing) sales as opposed to out of area, or other deficient (not good comparable) high sales?

Where are the directions to your clients telling them what the requirements for a reconsideration are? Your website looks like one of those amateur off the shelf, out of the box kind that misleads users into thinking there is no such thing as Dodd Frank Appraiser Independence requirements, or FNMA CU licensing restrictions.

I find it difficult to believe that you have appraisers involved in the daily operations of your firm, or they would know better than to allow this kind of open invitation for spurious reconsideration requests.

If this is how superficially you consider your obligation to comply with USPAP and Dodd Frank, not only will I not perform any work for your firm, I will urge others to avoid you as well.

By the way, what are “concierge appraisal services?” Made to order values? Guaranteed automatic intimidation for any appraisals that the clients don’t like? Diversified formats that may or may not encourage USPAP compliance?

I am forwarding your panel invitation to appraisal discussion forums as an example of how NOT to attract competent appraisers; and yet another example of why AMCs are held in such low esteem.

I’d extend a polite best wishes close to you, but it would be insincere. I do not wish your firm any degree of success as long as you think your website promotes good appraisal OR client practices.

Mike Ford AGA, GAA, RAA Realtor(r)
Chairman, National Appraiser Peer Review Committee
Vice President, Special Projects
American Guild of Appraisers
#42 OPEIU, AFL/CIO

Subject: Invitation to join our panel
From: “East2West Valuation Services”
Date: Tue, January 16, 2018 9:56 am

Dear Appraiser,

We are reaching out to extend to you an invitation to join our panel of valuation professionals. If you are not already on our panel, we invite you to take a moment to read about East2West Valuation Services.

We are a fast growing group of valuation professionals that specialize in providing concierge service to both our clients and appraisers. East2West was created by a team of appraisers and mortgage professionals who understand the industry and know that valuation is more than just a pay per file job. We are about building successful partnerships with appraisers. At East2West we know that our success is dependent upon providing support and opportunities to ensure your success!

By partnering with East2West, you have the following advantages; a team who values appraisal knowledge and expertise, pays invoices on time, and will never charge a technology fee. East2West is committed to open communication, transparency and support.

To join our panel, just hit CTRL + CLICK to  the link below (or copy and paste the link into your browser):

https://e2wappraisals.spurams.com/AppraiserSelfRegistration.aspx

To get started please provide a signed copy of your W-9, and scanned copies of your current license and E&O insurance.

Feel free to reach out to us if you have questions.

We look forward to a future with you!!!

Your team from East2West
East2West Valuation Services
www.e2wappraisals.com
Phone: 866-329-2621
Email: service@e2wappraisals.com

Michael Ford
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Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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21 Responses

  1. Joy Smith on Facebook Joy Smith on Facebook says:

    Following

    4
  2. Avatar J. West says:

    Got the same email and yes they look like another amateur out of the box AMC.

    7
  3. Avatar Sonshyn says:

    Wow!  Consider they are advertising as Appraiser and Mortgage Consultants created this company they should know better.  They should use the knowledge that they hated to make a better business than the current AMC’S are offering.  No thank you!  

    5
    • Baggins Baggins says:

      On a side note, click the app link though. That’s the new alternative which is way better than mercury, ap, scope, and all the rest, that I was talking about previously. Without saying anything about the company being discussed, I find that particular distribution platform to be preferred above all others. Picking a better distributor platform which does not charge appraisers tech fees is at least a good start.

      3
    • Avatar Donna Corrado says:

      They were poor appraisers getting no work so they became AMC’s What a joke!

      1
  4. Avatar John Pratt says:

    Mike I got the same request from this AMC(?). It is apparent that this company doesn’t have a competent appraiser on staff. They apparently think that just because the loan officer, real estate agent, borrower or whoever doesn’t like the value on the appraisal report they can ask for a “Reconsideration of Value”. By the way I did NOT respond to their request. I have a policy, all reconsideration of value requests must be reviewed by the lenders underwriter and that underwriter must provide me with the MLS printout and property data sheets for each of the sales they want me to consider and state they have reviewed this information and believe that these sales may be superior to the comparable sales cited in the report. I require the name, title and phone # of the underwriter be provided to me and I will not proceed with the request until all of this information is provided.    

    10
    • Baggins Baggins says:

      By using non licensed staff, their is no individual whom is in a position to say no. The request after all, comes from their direct employer. Individual appraisers licensing for ALL distribution workers ought to help clear that up.

      7
  5. Baggins Baggins says:

    Why exactly is the order distribution clerk staff given information about deals and personal information of interested persons anyways? Suggestion; If FNMA is going to revamp forms, please include development of an official ROV form, with all the associated requirements and certifications necessary, to be signed by the party issuing the ROV in the first place, to be included in the loan file.

    This solicitation at least has no technology fee. That’s great. Now if only they guaranteed direct assignment ordering, rotational and fair distribution for all appraisers on panel, promised not to use bidding approaches to routine order distribution, clearly stated a fixed fee for their services, and promised 2 week minimum turn time allowance on all full orders…  Dare to dream.

    7
  6. Avatar Fritz Vogel says:

    I got the same offer over the weekend, I just hit delete, I didn’t bother to read it. It’s a new 2018 year and all the same “animals” in the zoo are seeking to replace appraisers they screwed last year. Nothing new other than the year. Just having a drop down for an appraisal “Problem” right of the bat indicates it is a “Problem” for them or else why put it out there right away. So, the way I see it, each assignment is going to become 2, the first valuation and then the  reconsideration valuation, all for the price of one, I can’t wait.

    7
  7. Avatar Jack Of All Trades says:

    I’d rather burn in Hell than work for this degenerate AMC 

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  8. Avatar Bill Johnson says:

    Although well intended, the VAs Tidewater program is worse in my opinion than any post submittal conventional reconsideration of value request. One e-mail to the POC sets off a flurry of group e-mail activity where’s its clearly the appraiser against everybody else. Without a review of the completed appraisal, the appraiser is forced to in advance become the teacher/educator to all those who are not our intended client. Although differences in opinion can never be fully removed, if the system results in 99 hours of wasted/unpaid appraiser time in advance of sending out the report, the random one hour in a hundred issue is to expensive for the result. That is, if anybody was paying for our extra time in the first place, which they are not. 

    5
    • Avatar Pattie P. says:

      I’ll have to “beg to differ” on that one Bill. It’s been my experience since being added to the VA fee panel in the late 90s that the Tidewater rule works very well. If I’m having difficulty in  justifying a contract price I simply let the lender know and put completion of the report off for 48 hours to allow the interested parties to provide support for the contract price. They are REQUIRED to grid  comprable sales that they have for me to consider. In this way, I am not bombarded with 50 irrelevant comparable sales. There is no way a real estate agent is going to grid 50 comps! This also lets the interested parties know what I am up against in trying to justify the contract price. Once the comps are received from the lender (all supporting information is to go through the lender and forward to me) I then check to see if I’ve already considered them in my first submission. Many times I have and they still do not support the contract price. If by chance I have missed a comp that is as good or better than the ones I have used I will include it. I have no problem with this. Sometimes that extra comp has an effect on my final opinion of value. Sometimes I will not consider any of the comps submitted because they are inferior to the ones I’ve already selected and we’re clearly selected for their sale price and not their similarities. I have found that those employed with the VA are actual appraisers and know what they’re talking about. They back me up when I am right. The VA wants what’s best for the veteran . When I work for AMC’s and have this issue, they AMC’s in many cases try to intimidate me into using inferior sales to inflate the value. They rarely attempt  to back me up. In many cases  the people that I’m dealing with at the AMC are not qualified to even discuss the appraisal with me. Appraisal management companies DO NOT have the consumers best interest at heart. They just want to make the deal work and pacify the lender. Nope, the VA has it right Bill. I know from experience.

      9
      • Avatar Bill Johnson says:

        As I said Pattie, the system has good intentions, but in my opinion, is still flawed. If you say “I’m having difficulty in justifying a contract price”, but in realty perhaps no problem in establishing an independent opinion of market value (appraised value), then why invite an angry group (agents, borrowers, owners, LOs, etc.), the opportunity to influence your opinion/work in advance of completing it? In addition, even if Tidewater is done by the book (3 gridded sales), I find the process of explaining why I didn’t use something (certain sales), counterintuitive to the actual intention of the appraisal which is to provide support for my independent opinion of value. My opinion is not a knack on the big picture VA appraisal system or the veteran, but if in my experience 99 hours is wasted to find that one hour problem, then lets find the one hour after the work is completed, so 99 hours are not wasted.

        4
  9. Avatar Dave Towne says:

    Back to Mr. Ford’s original post, which has nothing to do with VA.To play devil’s advocate, the contention is the checkbox the AMC provides somehow diminishes the value of the appraiser’s opinion. Actually, those checkboxes correspond with what was allowed in HVCC, which was carried forward into Dodd-Frank. Anyone connected to the ‘deal’ can question the appraiser’s value, but must be based on poor comparable selection or a significant obvious problem in the report. That’s what the checkboxes do.The biggest question to answer is whether or not one wants to do business with any AMC, especially those on fishing expeditions. I choose to be very selective. But the fact is, most residential appraisers across the US do work for AMC’s.  It’s the unfortunate situation we all face in order to keep our business up and running. I know this from a comment I made to a room full of appraisers at the Appraisal Summit & Expo this past November. I asked the attendees how many of them did assignments for direct placement local lenders, Credit Unions, etc. Not one hand went up out of 250 or so people in the room.  Sad commentary. That seminar had to do with why we appraisers had to do a better job and have a better attitude working for AMC’s……….which most of us abhor.

    2
    • Avatar Wayne Courtney says:

      We just do not know what tomorrow will bring. I may hit the lottery or die of cancer. There is one thing I feel is absolutely certain in my life. That is I will NEVER attend a seminar that “had to do with why we appraisers had to do a better job and have a better attitude working for AMC’s” Really?

      —- Matthew: 15:13-14 “If the blind lead the blind, both will fall into a pit.”

      4
    • HVCC was rescinded. FNMA license requirements require more than check boxes. As an appraiser just show me 2 or 3 ‘better’ or “as good” comparables and comment about WHY they support a higher value and I will reconsider openly and honestly every time. Shotgun a load of garbage at me and it goes in the figurative e-waste bin with an automatic “No change response.”

      1
  10. Avatar Fritz Vogel says:

    Any system were a “LOW” value will be involved, opens Pandora’s Box of horrors for the Appraiser. 10,000 worthless comps from a Realtor, Stips up the rear end from an AMC” BECAUSE” it came in low and a Low ranking of the Appraiser in every ones eyes, regardless of the accuracy of the report. It seems (OR IS IT JUST ME) That when there is a problem, a fine tooth comb comes out and attempt’s to find any possible errors in a report. The VA has a good system, but most don’t read or receive the original report BEFORE they pull out the pitchforks and saws. Sad state of affairs.

    6
  11. Avatar Fritz Vogel says:

    Don’t shoot the messenger comes to mind.  But someone has to put a value on “It”.

    4
  12. Avatar Anna R Todaro says:

    I am both a Certified Appraiser and Realtor. While I am well aware of the ignorance of lenders as well as agents of what appraisal standards appraisal reports are to uphold, I also have personally seen some appraisals that seriously missed the mark. For my Realtor friends, I have helped them compose letters clearly laying out the reason for requesting a value reconsideration, and they receive them quickly. I have also advised agents when the appraisal was accurate and should not be disputed. In my opinion, it is not a sign of a bad AMC having those choices for a reconsideration of value and I would not disqualify them from my potential clients for it. Mr. Ford does point out however that they need educating on the basis for requesting a reconsideration of value. Appraisers can close the gap in this area by working with agents and having advisory sessions with local brokerages. It is a win-win for both when we do this.As for the comment that appraisers need to learn to work with AMCs. I find that ironic. If the first AMCs in existence valued appraisers, we would see a different working environment. From the start of my working with any AMC (RELs was my first), I never experienced any appreciation or respect for my work. I often thought about it in comparison to my grandparents experience with the coal mines. I am from the Appalachian Mountains originally. Both my grandfathers died in their 50’s from black lung. They were very poor and owned little. I have friends from Virginia and Kentucky whose grandparents died still owing the Company Store. Somehow the appraisal profession adopted the mentality of the Company Store and coal mine industry. Appraisers were seen as expendable, replaceable, and- quite honestly- a necessary pimple on their hind end. Due to the high level of education and experience required for our profession, many looking for a quick buck or for a profession having appreciation shown both in money and respect from the clients, dropped out or chose a different career. Now AMCs are reaping what they sowed for more than 10 years and instead we are holding classes to tell appraisers how to work better with them? Now that is ironic if you ask me.

    5
    • Anna, we have all seen ‘bad’ appraisals. It would be intellectually dishonest to say they don’t exist; or that there is never a valid reason to dispute, or at least question a value.

      Having said that, it is also true that the vast majority of reconsideration requests have absolutely no relevant new information. We are human beings. As such we can make mistakes. When we make a mistake the honorable thing to do is to acknowledge it and correct it….though run away rogue state regulators now make even innocent, simple mistakes into USPAP violations.

      Bottom line, is that any request for reconsideration or value dispute should have some factual basis for being made. We appraisers also should not be afraid to change our opinion when “…information not previously available in the normal course of business” becomes available; and supports such changes.

      ANY AMC that fails to provide such a basis or at least show they had a discussion about it with the appellant doesn’t deserve any further consideration. They are proving incompetence and laziness.

      3
  13. Avatar Dave Towne says:

    Both Wayne and Anna are correct.  At each of the past Summit/Expo’s I have attended (2017 & 2015), there have been seminars presented from the AMC’s perspective of how ‘we’ should interact with them.  At both I stood up and suggested to the AMC presenters that THEY should change their attitude about working with “US” appraisers.  Of course, the response has been a typical ‘deer in headlights’ look, as if THEY know everything, and we appraisers are merely the peons in the entire process.  Most appraisers, I believe, would rather work directly for the lenders – if and only if – the current Appraisal Independence Requirements would absolutely apply to them without bias or negative influences …… not like it was in the wild west prior to HVCC.  The problem is most lenders have jettisoned their appraisal departments in favor of AMC’s in order to off-load the personnel cost of maintaining an appraisal department.  But some wiser lenders are beginning to realize the AMC model does not work to everyone’s advantage in all cases.  That’s why Wells Fargo fired RELS, and started their own in-house appraisal department again.

    4

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Reconsideration of Value Requests

by Michael Ford time to read: 3 min
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