Appraisal Waivers

Appraisal Waivers Meeting... Self Serving Risky Practices Going Forward

TriStar Bank’s request for appraisal waivers: The Appraisal Subcommittee has reached out to the Network Coalitions and has requested appraisers to attend their upcoming meeting on appraisal waivers.

Direct from the ASC announcement:

ASC Special Meeting – April 12, 2018
Tuesday March 06, 2018
The ASC will hold a Special Meeting scheduled for 10:00 a.m. on April 12, 2018, at the Federal Reserve Board facilities at International Square, 1850 K Street NW, Washington, DC. The purpose of this Meeting is to consider the temporary waiver request from TriStar Bank of Dickson, Tennessee. The agenda for the Meeting will be posted here approximately two weeks before the meeting date.

If you plan to attend the ASC Meeting in person, we ask that you send an email to You may register until close of business four business days before the Meeting. You will be contacted by the Federal Reserve Law Enforcement Unit on security requirements. You will also be asked to provide a valid government-issued ID before being admitted to the building.

VaCAP sent a letter expressing our concerns and has jointly signed the Network of State Appraisal Organization’s letter of concern and a joint letter with 35 state and national appraisal organizations as well. The Appraisal Foundation also sent a letter expressing their concerns. We encourage every appraiser to comment on the request and if you are able to attend the special meeting on April 12, please do so. It is important for appraiser to be present to show support and express concerns.

See VaCAP’s, NSAO’s, TAF’s and AI’s letters below.

Senate Bill 2155 has passed the Senate. VaCAP signed a joint letter with the Appraisal Institute and other State Coalitions. See the letter here. Some clarifications were added as a result of our joint efforts. See the entire bill here.

The clarifications are a step in the right direction, however, the language is still present and allows the waivers. We need to have this language removed. It is time to contact the House of Representatives to have the entire section removed. Find your representative here.

Barney Frank weighed in on Senate Bill 2155.

As a Reminder, make sure you talk to all the agents in your database. Agents who allow their buyers and sellers to move forward with a purchase or sale in which an appraisal is waived may be accepting the liability of the value of the property. Phil Crawford spoke to John Torvi with Landy Insurance recently on Voice of Appraisal. Attorney’s are waiting to pursue action against agents and Brokers over this. Listen to Show E193 here.

VaCAP Board
VaCAP Board

VaCAP Board

Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.

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16 Responses

  1. Barney Frank had such a stellar record for sound financial practices, we can certainly take his word for it. Now I’m MUCH more concerned than I was before.

  2. Baggins Baggins says:

    The system of requesting waivers will be abused from day one. Be it fictitious paperwork, manipulation in requests, or other further pressures to put appraisers out of business, when waivers come forth every non accountable distribution person will get bonus commissions for finding a way to push those waivers through. Every single person in the appraisal distribution positions should have appraisers licenses or there will be no accountability in the waiver, or any other distribution based process.

  3. Avatar MIke says:

    I was in a NAR Ethics class yesterday and I mentioned the waivers and the liability the agents may have if they do  not advise their clients to obtain an appraisal., The instructor agreed 100% and there were lots of questions from the agents after the class. I spent about 45 minutes talking with them about what was going on. I further explained that it was crucial for the agent to perform their due diligence and actually look at the comparable sales and base their advice and guidance to the purchaser based on the comparable sales, not what the seller has listed the property for. About 1/2 of the agents stated they did not do a market search to advise the purchaser. Hopefully it made a difference or at least made them think.

    • Great job Mike. We all need to reach out and try to help educate those agents that are open to being educated. Many really really are sincere professionals that just want to do their job right. We only focus on the horror stories as a rule.

      • Baggins Baggins says:

        Until they get into portfolio lending they’ll remain toothless, just like appraisers. There are no real rules in the realm of origination, only a complex bureaucracy with a million and one work arounds. Ever heard of an appraisal distributors ethics group? Of course not.

  4. Avatar Advocate says:

    Every appraiser needs to contact their representatives and comment to the ASC on the TriStar waiver request. The more they hear how wrong it is, maybe they will start to listen.  If you are in the area for the ASC meeting, please make sure you attend to express concerns.The more appraisers are vocal, the more we are heard!

    • Baggins Baggins says:

      No, votes are for sale. Contacting an advocate masquerading as an elected official whom has already been paid by the lobbyists won’t accomplish anything. Warn the public. If the representative democracy system functioned correctly, we would not be here now.

  5. Avatar Anna R Todaro says:

    Stated income loans are back. Now add in appraisal waivers… Do you need a crystal ball to see where this is heading? A shortage of appraisers is a lie. A shortage of appraisers being paid a reasonable fee is the truth. Pay the appraiser what they are worth to give their unbiased opinion of market value and you will be a long way toward making reliable loans. All appraisers in the DC area on April 12th should be attending the ASC meeting. Even if you cannot attend, take a moment to send a comment stating the concerns appraisal waivers raise in the market.

    • Avatar Advocate says:

      Welcome to 2005! I have come across situations where the 1st mortgage is 80% with a 20% second, then a third lean for closing costs. We can blame the lenders all we want (and we should), but lets be honest, if the borrower is accepting these terms, they must take some of the responsibility as well. The question is not will the market crash, but when will the market crash.

      • Baggins Baggins says:

        Some of us are not just trying to save this specific checks and balances profession called residential appraisal. Some of us are fighting tooth and nail to protect the liberties associated with private property and home ownership. In reality, uneducated risk taking consumers are the biggest danger to the appraisal profession. Lenders, being naturally predatory in nature, are standing by to take advantage of them. Surprisingly, consumers continue to line up no matter how many times they’ve been washed out. So why not qualify them on different terms, so many of them will default anyways regardless of terms.

  6. Avatar Robert Burkley says:

    Housing is one of the most important investments in peoples lives. Why would you ever want the Mortgage / Appraisal / Financing of this critical investment become “Cheap and Fast”! Cheap and Fast is okay for Fast Food, Dollar Stores, Pawn Shops ………… but not your most important store of wealth. Does the process really take that long?? Important decisions in life take should time. Analyze the options and use due diligence!! 

    • Baggins Baggins says:

      Until we apply cash equivalency or borrowing power and price equivalency to the analysis based on disclosed rate, the beat will skip on. It’s one big illusion anyways, the fed manipulates the rate to appease a limited array of powerful vested interests, boosts purchasing power one day, then constricts access and stressed the market the next. One thing is for certain though, the lenders profit on both sides of the coin. Big picture newflash for everyone, these lenders borrow at a negative rate from the fed so they profit from literally doing nothing and actually don’t need customers. When they’re engaging, it’s for their best interests one way or another. Individual consumers can win with careful strategy but most who rely on double dipping and some specific rate level which works with their affordability factors are in for a cold surprise, probably sooner than later.


  7. Baggins Baggins says:

    This just in, you’ll love this one.

    Civxdata, data typing service.

    Whois data; 10 dollars a report, from Mumbai in India, a subsidiary apparently of; signature value group.

    Some interesting data on this apparent shell company known as signature value group; ‘FTB suspended’, from what I can gather, they failed to report taxation properly.

    That’s who appraisers will trust to complete their report write ups?

    Another clear example of devious shell companies operating at slash rate, violating data privacy, causing likely harm to the American public through their unscrupulous use by unethical appraisers, marketing specifically to appraisers. Read up on some of their quite bold obviously false claims;

    Greetings from CIVXDATA a business entity of RAPID APPRAISAL MANAGEMENT SYSTEM a California based corporation.

    CIVXDATA is a full appraisal data entry service, and is a unique tool to help today’s busy appraiser. Over the last few years the amount of time spent on completing appraisal reports has increased for the already overloaded appraiser, this coupled with lower fees has created the need for appraisers to find tools to increase report turnover. CIVXDATA can be the assistant you wish you had for a fraction of the cost. We will complete appraisal forms 1004, 1073,1025,1004C and 2055 for only $10 per report.

    We have been entering data on 1000+ appraisal reports every day with high rating standards with respect to accuracy, turn time and technology.

    In a span of four years we have a satisfied clientele of 400 satisfied individual appraisers and subcontracting AMC’s. In this small journey of ours we have helped many of our clients get better grades from their AMC clients by completing reports faster with NO rejections.

    Our completed report shall have the following sections completed:
    • Subject Contract (If applicable)
    • Neighborhood (Neighborhood boundaries)
    • Site (Dimension/Area/Shape/View/Zoning Info/FEMA Info)
    • Improvements (General Description/ Foundation/Exterior/Interior/Attic/Heating Cooling/ Amenities/ Garage/ Finished area above grade/ Property Condition)
    • Sales Comp (All sold and active listings)
    • Prior sales history
    • 1004 MC
    • Subject/Comp photographs
    • Location Map
    • Plat Map
    • Flood Map
    • Zoning Map
    • Subject Sketch
    • Subject Photo’s

    Turn-around time: Normal-12-15 Hours
    Rush: 6 Hours
    Super Rush: 3 hours

    Do what you enjoy the most- Appraising Properties NOT Typing Reports!!

    No wonder lenders want waivers, many appraisers are turning in crap work from india slave laborers. I get 2 reports done a week, by the book, completely solo, the right way, the careful way, the ethical way. For the complete morons out there, you can’t complete an appraisal ethically and properly unless you actually do the work. How in the hell can you ‘do an appraisal’, without all the work behind it? Clearly the blind leading the stupid with these services. Requested new FNMA form mandatory entries; Used any report assistant services? State which one. Inspected personally or used assistants? State whom. All of that, it’s a free for all and FNMA is hurting the public trust in the appraisal profession by not recognizing and prohibiting this sort of outsourcing activity. If appraisers need help, they should be limited to hiring that help locally. Appraisers that use outsourcing should quit now, they’re a complete embarrassment for the rest of us and have skewed normal performance expectations beyond the breaking point. This is the standard which the waiver program will hold the exceptions to. There are many examples but this is just one, why and how variable ‘performance standards’ used to measure the validity of a waiver request will be abused from the very first minute. 1 and 2 day turn times remain as a total joke to serious detailed appraisers. Can you guess what comes next? Amc’s using these companies, if they are not already which is highly likely.

    • Wait a minute! You mean to say that I have to pay $10 typing fees IN ADDITION to the $10 cost for Hyderabad Harry and Bangalore Bob to do the whole hybrid appraisal? How can a middle man possibly make any money that way? Why that’s outrageous! If they can’t get the combined costs down to less than $14.93 per report the hell with them!

      • Baggins Baggins says:

        Actually that would be through Mr. Bhikaji Kanse. From Mumbai, Maharashtra, India. Whois is a wonderful research tool. It’s easy to use and it can lead to a lot of information. Enter the tax dodging shell company US state side to bypass regulatory restrictions on brick and mortar companies. That would be either Signature Value Group, Rapid Appraisal Management group, or both. Would not put it past any of them to be tied into house canary, data master, even Corelogic, or a mix of any of those. Outsourcers outsource themselves these days. Trust no one. Real appraisers do the jobs themselves or dole out work to trusted in house employees. The rest, faking it for big cash. The system of backwards rewards continues. The lingering question remains, how could they fill out all that data without direct access to one of the major data aggregators out there? One then suspects these are shell companies or spin offs themselves, possibly masking the fact that major players are likely engaging or supplying them with data, or both.

        Thanks for reading Mike, I could not resist posting that, landed in my spam box just today.

        • Baggs – You know that IRS has a Large Business & International Division right? (LB&I) and Treasury Inspector General for Tax Administration (TIGTA) takes reports and prosecutes criminal tax evasion. Those are the serious side of IRS – they carry guns AND calculators.

          It’s been awhile since I took the orientation courses but I think there are percentage rewards for turning in those higher levels of tax cheats. In fact when I was there foreign tax cheats and over inflated conservation easements were their two biggest targets.


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Appraisal Waivers

by VaCAP Board time to read: 2 min