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	Comments on: Appraisal Waivers and Hybrid Appraisals	</title>
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		<title>
		By: lance b		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28153</link>

		<dc:creator><![CDATA[lance b]]></dc:creator>
		<pubDate>Wed, 09 Oct 2019 22:54:23 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28073&quot;&gt;Jon Anweiler on Facebook&lt;/a&gt;.

You are not thinking ahead Jon, you should have a huge problem with the very thought of this product ever being used due to the fact this product opens the door to anyone writing a report from anywhere ... if you want to see how fast they can move your job to india keep doing the bifurcated appraisal work.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28073">Jon Anweiler on Facebook</a>.</p>
<p>You are not thinking ahead Jon, you should have a huge problem with the very thought of this product ever being used due to the fact this product opens the door to anyone writing a report from anywhere &#8230; if you want to see how fast they can move your job to india keep doing the bifurcated appraisal work.</p>
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		<title>
		By: Jamie Humphrey on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28142</link>

		<dc:creator><![CDATA[Jamie Humphrey on Facebook]]></dc:creator>
		<pubDate>Wed, 09 Oct 2019 03:53:40 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28139&quot;&gt;Susan Layne on Facebook&lt;/a&gt;.

Susan Layne not sure what you are talking about. I don&#039;t do hybrids.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28139">Susan Layne on Facebook</a>.</p>
<p>Susan Layne not sure what you are talking about. I don&#8217;t do hybrids.</p>
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		<title>
		By: Bryan J. Trenholm		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28141</link>

		<dc:creator><![CDATA[Bryan J. Trenholm]]></dc:creator>
		<pubDate>Tue, 08 Oct 2019 19:55:14 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28141</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28140&quot;&gt;Baggins&lt;/a&gt;.

Totally agree!! Who would have taken this job in the first place if that is what it was going to be. Not me. Although I do get tired of staring at my windshield from time to time, I do appreciate being out.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28140">Baggins</a>.</p>
<p>Totally agree!! Who would have taken this job in the first place if that is what it was going to be. Not me. Although I do get tired of staring at my windshield from time to time, I do appreciate being out.</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28140</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Tue, 08 Oct 2019 19:39:00 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28139&quot;&gt;Susan Layne on Facebook&lt;/a&gt;.

Quality of life is a primary draw for real estate appraisers. We trade a great many other benefits away for the liberty to decide how our time is spent. If I&#039;m going to be told the only way to make money is to sit at the desk all day long, I&#039;m immediately demand a 401k, paid days off, and other beni&#039;s. Totally relevant. If these products are so awesome why haven&#039;t lenders built up internal departments with staff employees whom churn out the products day and night?]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28139">Susan Layne on Facebook</a>.</p>
<p>Quality of life is a primary draw for real estate appraisers. We trade a great many other benefits away for the liberty to decide how our time is spent. If I&#8217;m going to be told the only way to make money is to sit at the desk all day long, I&#8217;m immediately demand a 401k, paid days off, and other beni&#8217;s. Totally relevant. If these products are so awesome why haven&#8217;t lenders built up internal departments with staff employees whom churn out the products day and night?</p>
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		<title>
		By: Susan Layne on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28139</link>

		<dc:creator><![CDATA[Susan Layne on Facebook]]></dc:creator>
		<pubDate>Tue, 08 Oct 2019 19:22:02 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28131&quot;&gt;Jamie Humphrey on Facebook&lt;/a&gt;.

Jamie Humphrey That’s nice, but Irrelevant]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28131">Jamie Humphrey on Facebook</a>.</p>
<p>Jamie Humphrey That’s nice, but Irrelevant</p>
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		By: Jamie Humphrey on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28131</link>

		<dc:creator><![CDATA[Jamie Humphrey on Facebook]]></dc:creator>
		<pubDate>Tue, 08 Oct 2019 02:59:48 +0000</pubDate>
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					<description><![CDATA[The field work is my favorite part! Who wants to be at a desk all day?!?]]></description>
			<content:encoded><![CDATA[<p>The field work is my favorite part! Who wants to be at a desk all day?!?</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28116</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Mon, 07 Oct 2019 18:59:52 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28112&quot;&gt;Baggins&lt;/a&gt;.

http://ronpaulinstitute.org/archives/featured-articles/2019/october/07/federal-reserve-s-latest-bailouts-more-proof-bad-times-ahead/

Fed continues to pump up the lenders economy. 75 billion digi cash injections a day while appraisers are told our greed and holding to traditional full fee service is hurting the lenders economy. How many full fee orders would 75 billion dollars buy? How many would that buy again tomorrow? Deminimis, waivers, hybrids, evals, it has nothing to do with cost and everything to do with control. People are starting to ask too many questions.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28112">Baggins</a>.</p>
<p><a target="_blank" href="http://ronpaulinstitute.org/archives/featured-articles/2019/october/07/federal-reserve-s-latest-bailouts-more-proof-bad-times-ahead/" rel="nofollow ugc">http://ronpaulinstitute.org/archives/featured-articles/2019/october/07/federal-reserve-s-latest-bailouts-more-proof-bad-times-ahead/</a></p>
<p>Fed continues to pump up the lenders economy. 75 billion digi cash injections a day while appraisers are told our greed and holding to traditional full fee service is hurting the lenders economy. How many full fee orders would 75 billion dollars buy? How many would that buy again tomorrow? Deminimis, waivers, hybrids, evals, it has nothing to do with cost and everything to do with control. People are starting to ask too many questions.</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28114</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Mon, 07 Oct 2019 18:12:37 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28114</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28085&quot;&gt;marion&lt;/a&gt;.

Great read. Thank you.

But you know how it plays out.  

Banksters get what banksters want.  

They are above the law and nobody will ever go to jail for mortgage fraud.

We&#039;re on our own.

Picked the wrong career again.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28085">marion</a>.</p>
<p>Great read. Thank you.</p>
<p>But you know how it plays out.  </p>
<p>Banksters get what banksters want.  </p>
<p>They are above the law and nobody will ever go to jail for mortgage fraud.</p>
<p>We&#8217;re on our own.</p>
<p>Picked the wrong career again.</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28112</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Mon, 07 Oct 2019 18:03:08 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28112</guid>

					<description><![CDATA[Colluding to defraud consumers has gone mainstream.]]></description>
			<content:encoded><![CDATA[<p>Colluding to defraud consumers has gone mainstream.</p>
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		By: Susan Layne on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28106</link>

		<dc:creator><![CDATA[Susan Layne on Facebook]]></dc:creator>
		<pubDate>Mon, 07 Oct 2019 15:41:20 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28099&quot;&gt;Mike Ford, American Guild of Appraisers&lt;/a&gt;.

Mike Ford, thank you also for your comments. There are so many issues with this concept, I hadn’t gotten as far as USPAP in my thinking- also since I am 100% resolved to Just say NO!]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28099">Mike Ford, American Guild of Appraisers</a>.</p>
<p>Mike Ford, thank you also for your comments. There are so many issues with this concept, I hadn’t gotten as far as USPAP in my thinking- also since I am 100% resolved to Just say NO!</p>
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		<title>
		By: Bryan J. Trenholm		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28102</link>

		<dc:creator><![CDATA[Bryan J. Trenholm]]></dc:creator>
		<pubDate>Mon, 07 Oct 2019 13:43:41 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28102</guid>

					<description><![CDATA[Lender orders &quot;Property Observation&quot; from AMC.  AMC engages whomever is the fastes cheapest &quot;Observer&quot;.  AMC fee + Observer fee.  Input proprietary format and photos in to magical Fannie / Freddie Algorithm.  Computer says they need the Appraiser.  Lender orders the Desktop Appraisal from the AMC who then orders from the fastest cheapest Appraiser.  AMC fee + Appraiser fee.  Where is the time and $$$ money saving coming from?  The AMC doubles its processing and fee I assume and now you have 2 fastest cheapest performers involved.  We have already received calls from people (Realtors) that are being told &quot;The Appraiser&quot; is coming and it isn&#039;t the Appraiser.  The general public has NO idea what is going on or who is walking through their home.  Craziness and to what end?  Let&#039;s shift the attention to Title Companies.  Is Title Insurance really necessary?  And from both buyer and seller!?  Aren&#039;t we insuring over the &quot;Search&quot; the Title Company did?  Are these insurance policies being used?  What percent of the time?  Why are they so expensive?  6 to 7 times more than an Appraisal!]]></description>
			<content:encoded><![CDATA[<p>Lender orders &#8220;Property Observation&#8221; from AMC.  AMC engages whomever is the fastes cheapest &#8220;Observer&#8221;.  AMC fee + Observer fee.  Input proprietary format and photos in to magical Fannie / Freddie Algorithm.  Computer says they need the Appraiser.  Lender orders the Desktop Appraisal from the AMC who then orders from the fastest cheapest Appraiser.  AMC fee + Appraiser fee.  Where is the time and $$$ money saving coming from?  The AMC doubles its processing and fee I assume and now you have 2 fastest cheapest performers involved.  We have already received calls from people (Realtors) that are being told &#8220;The Appraiser&#8221; is coming and it isn&#8217;t the Appraiser.  The general public has NO idea what is going on or who is walking through their home.  Craziness and to what end?  Let&#8217;s shift the attention to Title Companies.  Is Title Insurance really necessary?  And from both buyer and seller!?  Aren&#8217;t we insuring over the &#8220;Search&#8221; the Title Company did?  Are these insurance policies being used?  What percent of the time?  Why are they so expensive?  6 to 7 times more than an Appraisal!</p>
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		<title>
		By: Mike Ford, American Guild of Appraisers		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28099</link>

		<dc:creator><![CDATA[Mike Ford, American Guild of Appraisers]]></dc:creator>
		<pubDate>Sun, 06 Oct 2019 23:05:41 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28098&quot;&gt;Susan Layne on Facebook&lt;/a&gt;.

100% absolutely agree! Imho, none have said it better.

As an aside; the Head of the Georgia REA Board (appraisal section) D.S. Murphy recently cited a past common occurrence (re comp checks)  “I need to get $250,000 for this property, can you do it?” &quot;– We would be expected to answer then on the spot or at best get back to them within the hour. No amount of desktop research is possible for an appraiser to be able to answer that question. &quot;

If it is virtually impossible to provide credible, compliant information in an hour from a desktop, then how is anyone going to do it in the 15 minutes most often cited by promoters? Especially in proprietary formats that may limit one&#039;s ability to add necessary data?

If promoters lie about the most fundamental aspect of these phony products (how long they take to properly compelte), then what else are they lying about?]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28098">Susan Layne on Facebook</a>.</p>
<p>100% absolutely agree! Imho, none have said it better.</p>
<p>As an aside; the Head of the Georgia REA Board (appraisal section) D.S. Murphy recently cited a past common occurrence (re comp checks)  “I need to get $250,000 for this property, can you do it?” &#8220;– We would be expected to answer then on the spot or at best get back to them within the hour. No amount of desktop research is possible for an appraiser to be able to answer that question. &#8221;</p>
<p>If it is virtually impossible to provide credible, compliant information in an hour from a desktop, then how is anyone going to do it in the 15 minutes most often cited by promoters? Especially in proprietary formats that may limit one&#8217;s ability to add necessary data?</p>
<p>If promoters lie about the most fundamental aspect of these phony products (how long they take to properly compelte), then what else are they lying about?</p>
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		By: Susan Layne on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28098</link>

		<dc:creator><![CDATA[Susan Layne on Facebook]]></dc:creator>
		<pubDate>Sun, 06 Oct 2019 22:24:59 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28098</guid>

					<description><![CDATA[Refuse to participate, as I wish we all would. While I am invested in my profession as an appraiser, I would rather starve, or do any one of a thousand other more engaging &#038; rewarding jobs- because that’s the proposition- a job, than participate in this bastardized process.]]></description>
			<content:encoded><![CDATA[<p>Refuse to participate, as I wish we all would. While I am invested in my profession as an appraiser, I would rather starve, or do any one of a thousand other more engaging &amp; rewarding jobs- because that’s the proposition- a job, than participate in this bastardized process.</p>
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		<title>
		By: Anonymous		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28094</link>

		<dc:creator><![CDATA[Anonymous]]></dc:creator>
		<pubDate>Sun, 06 Oct 2019 18:18:23 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28092&quot;&gt;Herb Martin on Facebook&lt;/a&gt;.

Hey Herb,

Remember when the latest fads were: telephone jacks in every room of the house, speakers built in to walls and ceilings, Internet jacks in every room in the house, Shag carpets, Autumn gold appliances, All &quot;quality&quot; upgrades. How many exist as quality upgraded data in the databases today? All of them, because once there, the data isn&#039;t changed.

How quick will the next fad of internet wi-fi appliances, heat, doors, window and alarms fade away? They will, just like all other fads.

How long will those quality upgrades remain in automated valuations after the fads have faded?

Forever.

But heck, no better way to get to feudalism 2.0 than government sponsored private entity monopolies telling you what your investment/property/shelter from the weather, is worth, and what someone else can borrow to be able to buy from you.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28092">Herb Martin on Facebook</a>.</p>
<p>Hey Herb,</p>
<p>Remember when the latest fads were: telephone jacks in every room of the house, speakers built in to walls and ceilings, Internet jacks in every room in the house, Shag carpets, Autumn gold appliances, All &#8220;quality&#8221; upgrades. How many exist as quality upgraded data in the databases today? All of them, because once there, the data isn&#8217;t changed.</p>
<p>How quick will the next fad of internet wi-fi appliances, heat, doors, window and alarms fade away? They will, just like all other fads.</p>
<p>How long will those quality upgrades remain in automated valuations after the fads have faded?</p>
<p>Forever.</p>
<p>But heck, no better way to get to feudalism 2.0 than government sponsored private entity monopolies telling you what your investment/property/shelter from the weather, is worth, and what someone else can borrow to be able to buy from you.</p>
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		<title>
		By: Mike Ford, American Guild of Appraisers		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28093</link>

		<dc:creator><![CDATA[Mike Ford, American Guild of Appraisers]]></dc:creator>
		<pubDate>Sun, 06 Oct 2019 17:51:32 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=22849#comment-28093</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28092&quot;&gt;Herb Martin on Facebook&lt;/a&gt;.

Herb the analytical part absolutely cannot be done by a computer. There is not one single example of any AVMs being cross-checked with other systems AVM where the results come within 10% of each other on the same atypical subject property. Not one.

I have used 4 different AVMs on such a property and got 4 extreme range results of a $630k property. They ranged from $430k to $790k. 1 came within 10% but not 5%.

The first problem with automated analytics is they are only able to analyze about 70% of value related characteristics. It means that 30% is simply reapportioned among the factors they can analyze thereby tainting those factors as well. The next problem is that every such system relies purely on unscreened, &quot;public record data from assessors; OR from Corelogic which reinterprets data and misses hugely important items such as site size on a consistent basis. Zoning is usually wrong, as are site influences.

No such system can yet analyze the degree of view as perceived in a market or its impact. The same applies with external factors. These systems are currently in use as so called value verifiers or fraud preventers, resulting in numerous appraisers being turned into state agencies WITHOUT ANY BASIS IN FACT of having violated USPAP. When carefully reviewed, based on AGA&#039;s cases reviewed every single such alleged non-compliance of the appraiser by the AVM was found to be unsupported.

We have already been replaced by such systems for PIWs and appraiser review. They factor in hybrids as well. That&#039;s one of the many reasons hybrids are so poorly considered.

That we will be replaced by such systems is not surprising. FHFA already signaled in their original white paper on the topic that despite their own evidence to the contrary, that AVMS will be the future. This isn&#039;t the first time the Feds and GSEs have micromanaged appraisals to the detriment of the public trust and the profession. The UAD itself; HVCC and 1004MC are only the three most recent examples.

FNMA has a long history of turning market values into some other form of value. Remember 155 and 25% net and gross adjustments? Nonmarket limits imposed by FNMA until February 2015 Lender Letter. Same with the perceived 10% line item limit and the perceived 1-mile distance &quot;rule&quot; that was imaginary but never definitively refute by FNMA until 02/2015.

Real appraisers may be replaced by GSEs as you note, but that&#039;s only about 40% of total appraisal work. Those of us that adhere to principles will shift our business to consumer side purposes and litigation.

I&#039;m guessing one of the most common cases will be refuting AVM results in court in growing instances of systemic deception involving values.

Herb speak with real experts on the topic such as George Dell. Even George will tell you AVMs are only a tool in the arsenal of an appraiser. A tool that one has to know both how and when to use. It&#039;s not universal.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28092">Herb Martin on Facebook</a>.</p>
<p>Herb the analytical part absolutely cannot be done by a computer. There is not one single example of any AVMs being cross-checked with other systems AVM where the results come within 10% of each other on the same atypical subject property. Not one.</p>
<p>I have used 4 different AVMs on such a property and got 4 extreme range results of a $630k property. They ranged from $430k to $790k. 1 came within 10% but not 5%.</p>
<p>The first problem with automated analytics is they are only able to analyze about 70% of value related characteristics. It means that 30% is simply reapportioned among the factors they can analyze thereby tainting those factors as well. The next problem is that every such system relies purely on unscreened, &#8220;public record data from assessors; OR from Corelogic which reinterprets data and misses hugely important items such as site size on a consistent basis. Zoning is usually wrong, as are site influences.</p>
<p>No such system can yet analyze the degree of view as perceived in a market or its impact. The same applies with external factors. These systems are currently in use as so called value verifiers or fraud preventers, resulting in numerous appraisers being turned into state agencies WITHOUT ANY BASIS IN FACT of having violated USPAP. When carefully reviewed, based on AGA&#8217;s cases reviewed every single such alleged non-compliance of the appraiser by the AVM was found to be unsupported.</p>
<p>We have already been replaced by such systems for PIWs and appraiser review. They factor in hybrids as well. That&#8217;s one of the many reasons hybrids are so poorly considered.</p>
<p>That we will be replaced by such systems is not surprising. FHFA already signaled in their original white paper on the topic that despite their own evidence to the contrary, that AVMS will be the future. This isn&#8217;t the first time the Feds and GSEs have micromanaged appraisals to the detriment of the public trust and the profession. The UAD itself; HVCC and 1004MC are only the three most recent examples.</p>
<p>FNMA has a long history of turning market values into some other form of value. Remember 155 and 25% net and gross adjustments? Nonmarket limits imposed by FNMA until February 2015 Lender Letter. Same with the perceived 10% line item limit and the perceived 1-mile distance &#8220;rule&#8221; that was imaginary but never definitively refute by FNMA until 02/2015.</p>
<p>Real appraisers may be replaced by GSEs as you note, but that&#8217;s only about 40% of total appraisal work. Those of us that adhere to principles will shift our business to consumer side purposes and litigation.</p>
<p>I&#8217;m guessing one of the most common cases will be refuting AVM results in court in growing instances of systemic deception involving values.</p>
<p>Herb speak with real experts on the topic such as George Dell. Even George will tell you AVMs are only a tool in the arsenal of an appraiser. A tool that one has to know both how and when to use. It&#8217;s not universal.</p>
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		By: Herb Martin on Facebook		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28092</link>

		<dc:creator><![CDATA[Herb Martin on Facebook]]></dc:creator>
		<pubDate>Sun, 06 Oct 2019 17:25:56 +0000</pubDate>
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					<description><![CDATA[I totally disagree, the analytical part can be done by computer. That&#039;s what is going to happen, eventually the analytical part will be done in house by the lender with a computer. The only part of the report that can&#039;t be done with a computer is the inspection, the most important part of the report. The analytical part isn&#039;t worth the paper its printed on without a knowledgeable person doing the inspection.]]></description>
			<content:encoded><![CDATA[<p>I totally disagree, the analytical part can be done by computer. That&#8217;s what is going to happen, eventually the analytical part will be done in house by the lender with a computer. The only part of the report that can&#8217;t be done with a computer is the inspection, the most important part of the report. The analytical part isn&#8217;t worth the paper its printed on without a knowledgeable person doing the inspection.</p>
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		By: Mike Ford, American Guild of Appraisers		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28091</link>

		<dc:creator><![CDATA[Mike Ford, American Guild of Appraisers]]></dc:creator>
		<pubDate>Sat, 05 Oct 2019 22:44:45 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28073&quot;&gt;Jon Anweiler on Facebook&lt;/a&gt;.

Jon when you did uninspected property appraisals I&#039;m guessing you  disclosed what you did and did not do along with why. Something other than an SOW placebo comment. 

We have all done desktops, no interior inspections etc.. It is the manner in which we do them; our HONEST disclosures and our property-specific assumptions coupled with other sound appraisal practices that produced credible results.

Not one of which was advertised as &#039;taking from 10-15 minutes&#039; on average. Nor were we limited by proprietary software constraints about what we could or could not include.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28073">Jon Anweiler on Facebook</a>.</p>
<p>Jon when you did uninspected property appraisals I&#8217;m guessing you  disclosed what you did and did not do along with why. Something other than an SOW placebo comment. </p>
<p>We have all done desktops, no interior inspections etc.. It is the manner in which we do them; our HONEST disclosures and our property-specific assumptions coupled with other sound appraisal practices that produced credible results.</p>
<p>Not one of which was advertised as &#8216;taking from 10-15 minutes&#8217; on average. Nor were we limited by proprietary software constraints about what we could or could not include.</p>
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		<title>
		By: marion		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28085</link>

		<dc:creator><![CDATA[marion]]></dc:creator>
		<pubDate>Sat, 05 Oct 2019 03:11:10 +0000</pubDate>
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					<description><![CDATA[Have you read this letter written by lawyers?

https://www.nclc.org/images/pdf/foreclosure_mortgage/mortgage_servicing/real-appraisal-comments-83-fed-reg.pdf

It is a comment to raising the deminimus, but it shows that &quot;the people&quot; do care about appraisals,

Here&#039;s some highlights:

The agencies need data comparing the foreclosure rate for loans originated with appraisals versus evaluations.

Without independent data on the actual cost of appraisals and evaluations, cost savings cannot be a rationale for increasing the threshold.

There is a dearth of independent data on how often appraisals delay mortgage transactions and whether using an evaluation instead would have eliminated the delay.

There is no data comparing the accuracy of appraisals, AVMs, and evaluations.

There is no data on the impact of the recent adoption of 12 U.S.C. § 3356.A 2018 amendment to FIRREA created a new exception to the appraisal requirement for loans of $400,000 or less. It appliesonly to properties in rural areas if the originator cannot obtain a timely appraisal after contacting at least three appraisers in the area.  The agencies cite an appraiser shortage in rural areas as one reason for the threshold change,37and the new statutory threshold matches the threshold proposed by the agencies.  Therefore the impact of section 3356 will be directly relevant to the proposed rule.  The agencies should collect data on the loans made under section 3356 before granting a broader exemption to all regulated lenders.

Reliable appraisals are important for consumers and the economy

None of the factors underlying the 2017 conclusion have changed.

Consumers should not be expected to buy their own, separate appraisals.

and more.

It&#039;s a good, easy read, and should alert appraisers there are consumer groups that value the work of appraisers.]]></description>
			<content:encoded><![CDATA[<p>Have you read this letter written by lawyers?</p>
<p><a target="_blank" href="https://www.nclc.org/images/pdf/foreclosure_mortgage/mortgage_servicing/real-appraisal-comments-83-fed-reg.pdf" rel="nofollow ugc">https://www.nclc.org/images/pdf/foreclosure_mortgage/mortgage_servicing/real-appraisal-comments-83-fed-reg.pdf</a></p>
<p>It is a comment to raising the deminimus, but it shows that &#8220;the people&#8221; do care about appraisals,</p>
<p>Here&#8217;s some highlights:</p>
<p>The agencies need data comparing the foreclosure rate for loans originated with appraisals versus evaluations.</p>
<p>Without independent data on the actual cost of appraisals and evaluations, cost savings cannot be a rationale for increasing the threshold.</p>
<p>There is a dearth of independent data on how often appraisals delay mortgage transactions and whether using an evaluation instead would have eliminated the delay.</p>
<p>There is no data comparing the accuracy of appraisals, AVMs, and evaluations.</p>
<p>There is no data on the impact of the recent adoption of 12 U.S.C. § 3356.A 2018 amendment to FIRREA created a new exception to the appraisal requirement for loans of $400,000 or less. It appliesonly to properties in rural areas if the originator cannot obtain a timely appraisal after contacting at least three appraisers in the area.  The agencies cite an appraiser shortage in rural areas as one reason for the threshold change,37and the new statutory threshold matches the threshold proposed by the agencies.  Therefore the impact of section 3356 will be directly relevant to the proposed rule.  The agencies should collect data on the loans made under section 3356 before granting a broader exemption to all regulated lenders.</p>
<p>Reliable appraisals are important for consumers and the economy</p>
<p>None of the factors underlying the 2017 conclusion have changed.</p>
<p>Consumers should not be expected to buy their own, separate appraisals.</p>
<p>and more.</p>
<p>It&#8217;s a good, easy read, and should alert appraisers there are consumer groups that value the work of appraisers.</p>
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		<title>
		By: SB		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28083</link>

		<dc:creator><![CDATA[SB]]></dc:creator>
		<pubDate>Fri, 04 Oct 2019 20:04:14 +0000</pubDate>
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					<description><![CDATA[All you have to do is read an AMC&#039;s employee reviews to see how poorly their operations are run. It&#039;s become way too easy for a soon to be fired/laid off, disgruntled AMC reviewer to take out their frustrations on the independent appraiser with endless scope creep and BS revisions. When you see appraisal conditions roll in late in the day on a Friday afternoon...... it&#039;s pretty obvious they want to ruin your weekend.]]></description>
			<content:encoded><![CDATA[<p>All you have to do is read an AMC&#8217;s employee reviews to see how poorly their operations are run. It&#8217;s become way too easy for a soon to be fired/laid off, disgruntled AMC reviewer to take out their frustrations on the independent appraiser with endless scope creep and BS revisions. When you see appraisal conditions roll in late in the day on a Friday afternoon&#8230;&#8230; it&#8217;s pretty obvious they want to ruin your weekend.</p>
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		<title>
		By: Cotton Cornell		</title>
		<link>https://appraisersblogs.com/appraisal-waivers-n-hybrid-appraisals-false-narrative/#comment-28078</link>

		<dc:creator><![CDATA[Cotton Cornell]]></dc:creator>
		<pubDate>Fri, 04 Oct 2019 17:06:01 +0000</pubDate>
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					<description><![CDATA[I couldn’t agree with this article anymore. I complete over 500 appraisals per year. With over 20 yrs of experience in this business i have never received a qc which resulted in any material change in my analysis or value conclusion. The root of the problem is AMCs. AMCs provide no added benefit to the appraiser other than to skim over 50% of the appraiser’s fee. The easiest way to debunk appraiser shortages would be to question why AMCs broadcast assignments at below market rate. If there were truly an appraiser shortage the fee would be considerably higher than what I currently charge. The results of Fannie Mae&#039;s poor business decisions will ultimately affect the investors. I can only urge anyone with a 401k or IRA to avoid investing in companies which invest in mortgage backed securities. The risk is way too high and the yield does not offset the risk. Unfortunately our tax dollars will have to bail the GSEs again. The taxpayers are going to pay the price for these poor decisions. The cumulative is a result of too many non-appraisers and corporations  deciding what is best for the appraiser. I the appraiser assume the reputational and professional risk by accepting the GSEs poor decision making. I will not allow my profession to be dragged any lower. We are here to protect public trust and that is what I intend to do. Appraisers the fee is so pathetic to make it worth accepting any bifurcated work. If you are will to complete these scam bifurcated appraisals make sure you quote a fee that you are willing to lose your license over. My license is worth way too much to risk sanctions by the state or to aid in ruining our profession. The folks in DC need to pay attention as sitting idly by watching consumers being taken advantage of isn’t what’s best for our country and economy.]]></description>
			<content:encoded><![CDATA[<p>I couldn’t agree with this article anymore. I complete over 500 appraisals per year. With over 20 yrs of experience in this business i have never received a qc which resulted in any material change in my analysis or value conclusion. The root of the problem is AMCs. AMCs provide no added benefit to the appraiser other than to skim over 50% of the appraiser’s fee. The easiest way to debunk appraiser shortages would be to question why AMCs broadcast assignments at below market rate. If there were truly an appraiser shortage the fee would be considerably higher than what I currently charge. The results of Fannie Mae&#8217;s poor business decisions will ultimately affect the investors. I can only urge anyone with a 401k or IRA to avoid investing in companies which invest in mortgage backed securities. The risk is way too high and the yield does not offset the risk. Unfortunately our tax dollars will have to bail the GSEs again. The taxpayers are going to pay the price for these poor decisions. The cumulative is a result of too many non-appraisers and corporations  deciding what is best for the appraiser. I the appraiser assume the reputational and professional risk by accepting the GSEs poor decision making. I will not allow my profession to be dragged any lower. We are here to protect public trust and that is what I intend to do. Appraisers the fee is so pathetic to make it worth accepting any bifurcated work. If you are will to complete these scam bifurcated appraisals make sure you quote a fee that you are willing to lose your license over. My license is worth way too much to risk sanctions by the state or to aid in ruining our profession. The folks in DC need to pay attention as sitting idly by watching consumers being taken advantage of isn’t what’s best for our country and economy.</p>
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