Fannie Mae Waiving Appraisals
Property Inspection Waiver, getting back to the old days of fogging a mirror…
Effective 12/10/16, FNMA will have a new program in place which will allow LENDERS to waive appraisals on certain refi’s, if it is offered through the automated Desktop Underwriter (DU) loan documentation process.
See the attached PDF.
Key points from the PDF (emphasis mine):
Property inspection waiver (PIW) is an offer to waive the appraisal for certain refinance transactions. Property Inspection Waiver offers are issued through Desktop Underwriter® (DU®) using Fannie Mae’s database of more than 20 million appraisal reports in combination with proprietary analytics from Collateral Underwriter® (CU™) to determine the minimum level of property valuation required for loans delivered to Fannie Mae. Effective December 10, 2016, an enhanced PIW offering will be available to all lenders via DU.
The PIW offer will be considered on the transactions below:
- One-unit properties, including condominiums
- Principal residence, second home, and investment property transactions
- Limited cash-out refinance transactions up to a 90% LTV/CLTV for principal residences and second homes; up to 75% LTV/CLTV for investment properties
- Cash-out refinance transactions up to a 70% LTV/CLTV for principal residences; up to a 60% LTV/CLTV for second homes and investment properties
- Loan case files that receive an Approve/Eligible recommendation
In the real world, this means FNMA is becoming an ‘enabler’, relying on only their in-house collection of prior appraisal data and the CU process to rank those properties, so as to arrive at a “presumed” value of a property where the owners are requesting a refinance. This refinance loan has to rely on a prior appraisal of that property, coupled with a data base of similar properties, the CU, and market trends.
The problem with this is that the actual current status of exterior and interior quality and condition of the refied property is unknown, and may be quite different from what is presumed by the reliance on electronic data, and whatever lies the borrower tells the lender.
We’re getting back to the good old days (not so long ago) of fogging a mirror, to get a loan. Not quite as bad as the old liar and no-doc loans, but almost.
I guess no one at FNMA learned anything in 2008, 2009.
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Freddie Mac is going to be doing the same thing in the spring
Shocker… So we have contributed to our own demise providing them data for the last few years.
Or did we?
And when does the law suit happen where the Coalitions begin to sue for the free information we’ve granted to the C.U. and its users? That is “our” information, provided by request, that they are turning around and using for profit. Am I off base here?
Correction: That WAS your information.
To answer your question more specifically though: It (the lawsuit) doesn’t happen. Appraisers, state boards, appraisal organizations, and appraiser coalitions are all spineless, clueless entities who can’t seem to connect two dots much less an organized lawsuit or boycott.
Hope this answers your question.
RA/David, you know that’s untrue. There is a huge difference between being spineless and being caught in the Catch 22 of our legal system.
WHO would we sue? Obviously FNMA since they have best documented their own data theft up through 2014 for CU (and presumably ongoing), but who else? FHLMC?. Please explain where the court of jurisdiction would be? Would we have fifty different lawsuits with fifty different states rules? Or, would we have one giant class action federal lawsuit where FNMA would argue that the feds have no jurisdiction because they lack federal regulations that prohibit stealing our un copyrighted and unlabeled intellectual property?
How about on the basis that CU requires some form of “human intervention” to determine if the use of it’s additional data would result in a different result? SOUNDS like a review to me but lately states seem to be taking a different approach than they did 10 or 20 years ago on services called something else…even if they function as an appraisal or review.
Don’t misunderstand me. I absolutely WANT that type of lawsuit; but I keep hearing negative responses to inquiries about how feasible it would be. Why hasn’t CFPB engaged in such a suit? Yes, it is theft of product from us directly, but it is also charging the consumer for one thing (an appraisal), and then using the results of that appraisal for something else altogether.
Of COURSE CoreLogic and others would file briefs as interested parties. Heck they might even counter sue saying that OUR use of THEIR data paid for through public record subscriptions and MLS dues was an unauthorized use (admittedly that would be weak).
I think we’d still have a case from issues arising from our professional opinions…but the obvious counters would be factual data such as room counts; GLA, amenities and yes, even ‘market derived adjustments’ are all public domain. We’d counter that the measurement of those market derived adjustments is proprietary but Im not sure how far that would get us.
Anyone know any federally qualified attorneys willing to take this in or even an anti trust lawsuit (against banks, mortgage bankers, brokers and AMCs that bind us to a fee based on TRID)?
Seriously. 73,500 of us left. Surely we must have someone that knows decision makers in a deep pockets lawfirm?
Supportive data tidbit; 326474000 estimated 2017 US populace / 73500 appraisers = .000225%.
And we’re to blame for every financial crisis to do with mortgage origination! It’s tough to find current total MLO figures, or perhaps I don’t know where to look, but I found a relatively recent figure.
‘At the end of the first quarter of 2013, more than 10,500 federally chartered or insured depositories were active in mortgage originations, with more than 394,000 MLOs registered.‘
On average, there are 7 appraisers available per federally chartered insured depository. On average there are .186 appraisers available for each 1 loan officers. Basically loan officers outnumber appraisers over 5 to 1.
Don’t let the amc’s or mlo’s sell you short, it’s written plain as day on every wall. Appraisers are vital to checks and balances systems. Service shuttlers (amc’s) and mlo’s are a dime a dozen. I tried to also find total amc employee figures nationally but could not locate any. I’m convinced there will be more amc employees than actual appraisers soon, if that’s not a fact already.
“…appraisals will not always be needed if they agree to accept the DU findings.” Smells like mortgage fraud waiting to happen. This is another example of what will cause the market to crash again.
And they will be blaming appraisers once again im sure when it happens again
With the speak of next year seeing a net 30% (purchase / refinance) reduction in appraisals needed, and the government waiving off appraisals, why is the focus on a perceived shortage of appraisers? Thanks in part to the stealing of our data, 50% of the work will not be around next year. Wow.
Do any of you remember the song by Simon & Garfunkel The Sound of Silence? “words of the prophets are written on the subway walls…”
I am no prophet but I do not think any of us have to be in order to see the train wreck that is coming in this “occupation” within the next few years. I live in the Great State of Texas! Texas has 254 counties and by my calculations as of Sept. there were 74 counties with ‘0’ appraisers. There were 50 counties with 1 appraiser in each county. There were 24 counties with only 2 appraisers and so on, etc. There are also a bunch of us old dudes in TX! AGAIN, I am no prophet but how could anyone expect our “occupation” to thrive with all of the AMCs, Expo type stuff, appraisal organizations wanting dues, newsletters, etc. and other parasites feeding on the appraisers as if we were chum on a fishing trip? Even the “so called leaders” of our occupation sell us out for less than a dime. A sad situation!
Fannie Mae is broke and has been for several years. Your tax dollars and mine are keeping them floating at this time. Those of us that own stock in this pitiful corporation are delighted to see that at this moment each share of stock in FNMA is $1.74 (10/26/2016 @ 10:30) Gee are we getting wealthy now? (what a joke this company is!)
Once FANNY and FREDDIE use the data they have collected thru CU for about six months or so, they will find out that many appraisers have just given up and retired or changed occupations. Where are they going to gather the information for their database going forward? You know and I know that they are going to bust their financial ass again and beg congress to give them more tax dollars. The election is coming up soon…lets vote for some changes!
Im in Virginia and 47 years old…..I’m getting out now while I can. The end is coming. CU and waiving appraisals? Unbelievable……………..
Time to file a class action lawsuit. It’s our data. On the other side of the coin, I guess that means we won’t need AMCs anymore.
They have been mining our data for over a decade, this isn’t something new. We have allowed them to do it and that’s how the business has evolved.
JOE’S APPRAISALS, LLC APPRAISAL COMPANY, EXPRESSLY RETAINS ALL RIGHTS, COPY RIGHTS, TITLE, AND INTEREST IN ALL PATENTS, TRADEMARKS, TRADE NAMES, TRADE SECRETS, SOFTWARE, DATA, CONCLUSIONS, OPINIONS, VALUATIONS, OR OTHER INFORMATION INCLUDED IN, ARISING OUT OF, OR IN ANY WAY RELATED TO THIS APPRAISAL OR THE PROVISION OF APPRAISAL SERVICES TO THE NAMED CLIENT AND/OR INTENDED USER. THE APPRAISAL REPORT AND INFORMATION SUPPLIED BY THE STAFF AND/OR AGENTS OF JOE’S APPRAISALS, LLC APPRAISAL COMPANY IS A CULMINATION OF INTELLECTUAL EDUCATION, PROFESSIONAL EXPERIENCE, PERSONAL INVESTIGATION, AND KNOW-HOW, WHICH SHALL AT ALL TIMES REMAIN THE PROPERTY OF JOE’S APPRAISALS LLC APPRAISAL COMPANY. NO PERSON OR ENTITY SHALL BE ENTITLED TO BREAK DOWN, STRIP OUT, MINE, OR DISSEMINATE ANY COMPONENT OR PART OF THIS APPRAISAL REPORT, INCLUDING, BUT NOT LIMITED TO, ANY CONCLUSIONS, VALUATIONS, OPINIONS, OR OTHER DATA COMPILATIONS HEREIN. NOTWITHSTANDING, THE INTENDED USER AS DEFINED BELOW MAY USE THIS APPRAISAL REPORT AND THE CONTENTS HEREIN FOR THE LIMITED PURPOSE AND USE IDENTIFIED BELOW.
-THIS APPRAISAL IS COMPLETED FOR LENDING PURPOSES ONLY AND IS ONLY TO BE UTILIZED BY THE CLIENT/INTENDED USER (IDENTIFIED ON PAGE 1). IT IS NOT FOR THE USE OF REAL ESTATE TAX APPEALS, DIVORCE, ESTATE PURPOSES OR TO ESTIMATED INSURED VALUE. THIS APPRAISAL INFORMATION SHALL NOT TO BE ENTERED INTO A DATABASE WITH INTENT TO GATHER INFORMATION FOR PURPOSES NOT RELATED TO THIS MORTGAGE TRANSACTION WITHOUT THIS APPRAISER WRITTEN APPROVAL AND AN ADDITIONAL FEE MAY BE ASSESSED.
I think somone owes me some money for my data…..
This has never been answered properly; Does inclusion of such language in the report supersede the authority of the pre written SOW presented by the assignment client and/or the assignment agent on behalf of the client? Some argue you must alter the sow and get a signed return which is noted specifically and signed personally by the controlling agent of the client/agent, for such language to be applicable. It seems to be the applicability is almost coincidentally relevant based on the potential scenario which may arise. Think litigation vs state based inquiry. Two different animals.
The appraiser accepts no liability what so ever from any party, and all parties agree that by using this appraisal, yada yada yada. FYI, caps lock does not increase the legal applicability of the statements, just do everyone a favor and give that all caps approach up. It’s eye noying for sure.
How does CU take into account data that was provided by appraisers that have since been suspended, disciplined or had licenses revoked, it doesn’t they use a one size fits all approach, and I not have any appraisers I know ever released rights for Fannie Mae to become users of our data outside the intended use of the mortgage finance transaction at hand.
This is gaining an unfair business advantage, restricting trade in our market the primary market, and extremely deceptive abusive acts and practices all unlawful under the Federal Trade Comission Act. Fannie Mae and Freddie Mac need to be stopped and owe all appraisers relief restitution for the data they unlawfully gained and used. There has to be a lawyer within our profession willing to take this on for our survival
There is also a pay to play unwritten contract between Fannie Mae and mortgage brokers who want to operate as Correspondent Lenders when their operations lack the structure to be a true Correspondent and the Pay to Play is that the so called Correspondents have to upload all FHA appraisals to the UCDP as the UCDP is for conventional loans and those appraisals to support conventional loans with the intent to be sold to Fannie Mae is for NOT for FHA appraisals!!!! But this is how Fannie Mae database is so unlawfully large and how it will continue to grow with appraisal waivers in the conventional market because lenders are uploading FHA appraisals in substitute. This is the biggest conspiracy and unlawful trade I have ever researched.
I think this as well gains an unfair advantage over mortgage brokers that don’t play unfairly and abide by the rules and also gives support to bring suit under the organized crime act (RICO ACT) against Fannie Mae and those so called Correspondent Lenders and their Parent companies specifically CMG Financial and Stonegate Mortgage and the lenders under Natty Mac that Fannie Mae is a big investor in.
Google this image; FNMA government sponsored luxury.
Betcha 2 hamburgers and 1 bear pelt that trend is re occurring right now.
Sure we could do those things you suggest. We could also use the power of the purse and do everything possible in our personal power to escape mortgage lending and actually own our homes. Or you could do something even more effective and jump on the audit the fed train. Most people are summarily conditioned to disregard the immense power behind that simple call to action. Think twice if you want a sound economic system.
One of the most common questions I field from homeowners is; What is the smartest course of action, how do we stay ahead in mortgage lending, etc. My answer is always the same and very simple; The only way to beat mortgage lending is to not participate in mortgage lending.
The sad story is……look at the certifications we were FORCED to with each report.
Today…10/30/2016 the ASC reported the number of license’s that were not renewed as of 09/30/2016. As per my count there was a total of 380 people who said to hell with this crap! LOL. The month of September is not really one of the most popular months for renewal. At 380 per month times 12 months would equal 4,560 appraisers out of an estimated total of 75,000 would equal around 6% reduction in appraisers.
If thousands of existing appraisers are running away from this occupation what makes folks think that there are new idiots wanting to become appraisers. There are going to have to be some changes in order for this trend to become stable. Personally…I do not care. I am 65 and semi-retired. I cherry pick every assignment in between vacations. I do know that many of my friends really need to work more years before they can tell FANNY MAY to shove it!
This issue is not just an appraiser issue. How in the world can an AMC stay in business without appraisers? How in the world can all of these appraisal organizations exist without dues from the nitwit newbies? What if no one attends the EXPO or subscribes to the newsletters, webcasts, coaches, etc.? How are those parasites making big bucks working on the various state appraisal boards going to keep their jobs without enough appraisers to justify their cost? FANNIE and FREDDIE will keep on doing their thing as well as FHA and VA until their losses are too much for congress to pay.
We all know that there are appraisers that will sacrifice their first born to make an AMC happy. This group is determined to making AMCs wealthy even if it means failure for them! These appraisers are going to go down to the point of financial ruin and as a peer…I hope to see it very soon! It is going to be a very interesting few years going forward! There are those who are truly my peers and I do wish you the best!
Just read the appraisalbuzz, mysteriously delivered to my home. Something about corporate dirtbags trying to fit in too much appraisal work while complaining about actually having to take a minute to communicate with homeowners, and lifetime students claiming premier positions and trying to run this industry. Give me a break. Those jokers need to go back to the corporate cubicles and back to school for their 5th and 6th degrees. If you don’t have the time to consult with regular everyday homeowners, you have no legitimate place in this segment of the industry. “The moment you realize you should have been a salesman or mortgage broker instead.” Serves them right, I’m glad they’re disappointed.
Funny but not far from the truth.
The chick in the photo is actually Margaret Hamilton (no not the wicked witch of the west); but rather the genius MIT team leader who wrote the navigational coding for the Apollo space program.
Received a mysterious copy of the Appraisal Buzzard magazine last week as well. I used mine to line the bottom of a bird cage….quite handy. I’ve been out of the business for 7 years and I’ve moved twice during that time.
Perhaps it’s time for the Appraisal Buzzard to change it’s name to Appraiser Stalker.
Hello…I encourage all of my fellow appraisers to subscribe to: http://www.asc.gov … this will tell you each day how many of our fellow appraisers are no longer doing appraisals. There seems to always be two or three each day that have had their license revoked or suspended by folks that have not done an appraisal in months if ever! These folks sit in judgement of all of us and they do not have a damn clue but their self appointed position makes them feel superior to all of us. They need their ass kicked!
USPAP is the biggest crock of crap I have ever seen in my life! We take that over and over year after year dollar after dollar spent for what? We must be the most stupid occupation on this planet!
AMC’s….why in hell do you work for them? A month or so without any appraisers to earn them a living and they will go broke and go away. I am doing my part….what about you?
Are you going to sponsor a “NEW” appraiser??? Have you lost your mind?
FHA says that you MUST crawl thru the attic and crawl space of a home…These guys/gals earn 70 to 80 thousand dollars of your tax dollars each year sitting in an air conditioned office. They have NEVER crawled under a home or thru an attic in Texas in August when it is 130+ in the shade. But they have so little respect for the rest of us as to make this type of crap a requirement. I do not have to put up with this…why do you? You know that if you say HELL NO…you may get a bit of respect?
Even the software programs seem to hate us. Who do they say will pay the fee? If we do not answer in X hours it is us that may NEVER get an assignment again! Really?? If you are faced with this type of crap….do a little research and move to another location. Why starve in one location when you can earn a good living in another? There are areas where appraisers are very few and respected….why butt your head with other AMC chumps working for peanuts. Oh well….I will get off of my soap box for now. I do wish my peers the very best!
As license revenues decline expect citations; fines and revocations to increase. Cash strapped states have found a (short sighted) way to replace lost license revenue.
The non USPAP compliant ‘reviews’ sidestep meeting any known appraisal standards of performance by calling themselves investigative analyses or credibility analyses “similar to those used by AMCs all the time.”
Apparently walking, quacking and looking like a duck is no longer evidence something really is a duck anymore
California already does that. It’s the only way they can keep
the department running. FINES and big ones.
Another topic…anyone want to join me on a fishing trip to Belize? We have not picked a date yet so it is totally up for discussion. Belize is a pretty country and the people speak English and are friendly. It would be fun to have a group of appraisers joining together for some fun! We are not getting any younger and may as well have some fun! A dollar in Belize is equal to $0.50 US. They have jungle, mountains, Myan Ruins, a bar or too! LOL…check it out!
I am no tour guide but I have been to Belize a few times. Check out http://www.travelbelize.org
Unlike the AMC parasites…I am not trying to earn a dime…just would like to get to know some of my fellow appraisers from around the country. Really, no one is earning a buck whether or not you go. Just a very honest invitation to join a fun group!
Promote it as an Appraisal Summit (or Appraisal Expo South) and you can make the big bucks like Princess Joan Trice. If AMC CEOs are willing to go fishing you can always throw them off of the boat and say they fell overboard. Now THAT would be a productive Expo.
It would be great if it was offered as a USPAP class and/or Cont. Ed. marathon so it would be a tax deduction.
Jodi, we deserve CE credit for posting here. Tough crowd.
Save some cubicle space for the Appraiser Coach Dustin Harris as he will want a booth on the boat so he can sell his mugs, promote company A, B, or C and encourage you to join his all star team so you to can complete 3 to 8 appraisals per day. Do you want to buy a DVD?
That guy gets a bad rap. All he’s doing is taking advantage of the advertisements for typist services which occupy every other page of the workingre magazine. Of course I object, but really, there should be a standard that outsourcing typist services is unacceptable practice.
To Retired Appraiser….It will not do any good to throw AMC CEO’s off the boat as the sharks will not bite them! It is just professional courtesy!
To Jodi….Thanks for the tax deduction idea but why spoil a fantastic fishing trip with a bunch of USPAP crap?
To Bill…..Lets leave the parasites at home! This trip is for fun…I promise that I do not want to earn one penney from you and your family/group joining us. This is for fun…not profit. (I am sick of one appraiser feeding off of another)
This trip is just for all of us “pitiful” appraisers. We can go and have fun…bring family, friends, etc. If we do this in February…just think about all of our YANKEE friends that would like to see beautiful blue water instead of snow. Remember that Belize is a world class fishing spot. Mostly catch and release! They have many caves to explore, Kayaking/canoeing, jungle tours, lots of good food! This is NOT a cheap trip…but it is NOT as expensive as a trip to London or Germany. Expect to spend about $1,000. maybe as much as $1,250. depending on your tastes, per person for airfare, lodging, food, fishing boat with guide, etc. everyone should verify their own price as if you are coming from BFE…may cost more! LOL
Just checked…round trip from Hobby to Belize in February…5-7 days was quoted at $411.00. By the time you add a few room nights, meals, fishing charter, taxi and whatever else that may interest you the price will run up to $1,000 to $1,200 per person. Do not go if you do not intend to have a hell of a lot of fun!
Cross the American border the wrong way on purpose? You might not get back in. Is there a TSA free travel plan available? If I want to go fishing I’ll just walk on to the lake with the old ice pick and short pole. I like the winter. No bugs. The problem with tropical climates is the bugs never die and grow bigger and bigger and bigger.
My belief is that the confidentiality requirement covers it but that is merely MY interpretation. To me the mere fact that a borrower is refinancing a property, going through a divorce or any other intended use is their personal business. Those that disagree will parse their use of such services in the best possible light but in the end, the borrowers personal business is no longer being kept confidential or ‘personal’ when such services are used.
While you’re on vacation, be sure to bring your cell phones and call your Senators and Congressmen about PIW or it might be the last vacation you get for a while. Looking at what Fannie Mae is allowing for $75.00 is pretty extensive. I emailed my representative a couple of days ago.
To Baggins…..I had intended this post to just be a simple invitation to go on a fishing trip. Not just a trip to the pond but a world class fishing trip. I thought that some of us that post often could meet and become friends. Personally, I have no problem leaving the U.S. to travel to “some” other countries. I take my shoes off and the TSA likes me just fine. As far as winter is concerned …you are totally welcome to all of it! I like the sun, beach, sand, blue water and sky! I did not expect to have many folks interested in such a trip. I just thought that there may be a few fellow appraisers that shared some similar interests. As far as bugs…the weather in Alaska can get to 40 degrees below zero and the mosquitoes look like a cloud at certain times of the year! No big deal…..go do your own thing, wish you the best!
To GWS….no need to bring a cell phone. No need to call a senator or congressman. They are going to do exactly as they want to do without considering my opinion or yours. I am not happy with that but I accept the fact that they represent themselves and not us! If you are going to contact your senator or representative ask them to close Fannie Mae and Freddic Mac down and never to do it again! LOL
So, I guess the answer is to give up without even trying.
Sorry, not in my nature. Maybe that kind of thinking is what got
us here in the first place. I do agree that Fannie & Freddie need to be shut
down. I’ll try and work on that for you too.
Never be embarrassed of being the last appraiser standing. It’s a noble ambition and someone has to win the title in the end.
There are those with intuition and those who continue to believe they can spit in the wind and defy physics. For the most part however there are appraisers out there who are clueless about the future of appraising.
Hey GWS….for one I am not giving up without trying. I have tried over and over for years and years. I have butted that stump until there is no hair on my head. I came to the simple conclusion that some appraisers feed off of other appraisers. They sell them all type of snake oil, newsletters, expos, coaching, designations…and other foolishness! The sad part is that some of our fellow appraisers will slap you out of the way if you try to tell them how stupid they are being! OK…I say go for it…send your dues, your tuition, your subscription…send your money…send your money…HELL I do not care!
In my market…I have to admit that I cannot do one residential appraisal each day. However if I could at $500 per appraisal and five each week would equal $2,500 per month and that would equal $130,000 each year. Lets say that I am lazy (lol…not me) but only do 50% of that. It would equal $65,000 plus social security. Each of us have a different view from our window. For me…how in the world could I possibly do the highway department work, the county work, the city work, the school district work, water district work, the oil and gas, easement, etc.? There is just too much…may as well go fishing…join me! If you are a qualified appraiser and you are hungry…come join us in Texas. Sam Houston told his folks that they could go to hell as he was going to Texas! LOL May work for you too!
GWS Send me your email address and I’ll give you a list of Congressional contacts on both sides of the aisle for you to contact. These are real contacts-not generic website emails only able to be received if you are in the right zip code district for members.
Oh yeah speakn my language. Love the Caribbean. Great idea especially when things typically start to slow down and the cold weather is coming soon
Apologies for posting here-Webinar is tomorrow – I just learned of it. FREE HousingWire Webinar — Wednesday, March 1
I was originally mildly annoyed with my favorite National Membership Coordinator for sending me a link without telling me what it’s about.
This is for a webinar registration that features a cast of characters that alone makes it worth attending or watching.
It’s titled “What’s Going to Happen to Appraisers in 2017”. It’s to be moderated by Jacob Gaffney, editor of Housing Wire.
Usually I’m pretty careful about who I give an opportunity to pollute my mind but this cast of characters includes a truly noteworthy Rogues Gallery. Their bios are interesting.
Alan Hummel, Chief Appraiser First American Mortgage Solutions (Anyone remember the folks that bought ACI or developed PACE PRO?) Now for the good part:
I’m deliberately leaving the fourth off because I have no knowledge of them other than info that speaker is a reported partner in a multi county Florida appraisal firm owned by MAIs, and that he is a former Florida State Regulator.
Seeing who the featured speakers are helps us to better understand why the state of our profession is what it is today.
Prior collapse and bailout of financial institutions all had appraisals on the mortgages which defaulted. Many were fraudulent. I reviewed many hundreds nationwide involved in litigation and provided testimony in U.S. Federal cases. Use of Automated Appraisals will reduce the loans based on collateral values from appraisers who simply are enablers to fraud. Big Data and analytics simply trum labor. Called progress by many.