Freddie Mac Takes a Bite of the Apple
Freddie Mac Proprietary Messages in the UCDP
Not wanting to be left home from the party, Freddie Mac has announced that on June 30, 2015 it will begin providing new feedback on appraisals submitted to it via the Uniform Collateral Data Portal (UCDP). Like Fannie Mae’s system, the messages will be delivered to those lenders seeking to sell residential loans to Freddie Mac. Most of the feedback will be in the form of warnings which essentially alert a lender there are some inconsistencies between the submitted appraisal report and data that Freddie Mac already possesses (like public records).
For example, if the GLA differs by a certain percentage from public records, there will be a warning issued so the lender and appraiser can verify the GLA used is, in fact, correct. As most appraisers know, the GLA shown public records may be deficient, but it is also possible the appraiser included in GLA a non-permitted addition. Either way, the purpose of the warning is to point out the discrepancy so the lender and appraiser together can determine if the appraisal report contains the most reliable number. Warning messages may generally be over-ridden by a lender allowing the loan sale to proceed.
On the other hand, Freddie Mac has also identified a number of discrepancies which is considers to be fatal. One example of a fatal issue would be when the signature by the appraiser is dated prior to the effective date of the appraisal report. Fatal messages are just that and cannot be over-ridden by a lender; the issue requires correction before the loan sale can proceed. Up until now, even fatal hard stops could be over-ridden by a lender so on June 30th a fatal message will truly stop the loan sale.
Thus far, Freddie Mac is not saying it has created a proprietary database to evaluate appraisers or appraisals like Fannie Mae uses in the Collateral Underwriter (CU) or Appraiser Quality Monitoring (AQM) system. However, we have heard such an announcement is imminent once Freddie Mac puts the finishing touches on its new (and improved, no doubt) quality control system.
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Danny,
Thanks for the info. Funny as heck though, Â data that Freddie Mac already possesses (like public records).Â
Koma
I wasn’t too concerned at first. Then they said they are working toward something similar to FNMAs CU which is an abysmal failure.
Also, specific items are going to cause tremendous unnecessary work. FRE 1001; and 1014. Most of us don’t go into great detail for nominal size discrepancies. Additionally, what about new construction? PR shows a 1,235 sf 3 br-2.1 bath. The subject is brand new construction of 4,000 sf!
Read on through the rest. Many if not most can be avoided by us providing more thorough explanations (raise your fees folks!), but some of these are micro managing; or a level of computer conformity being required that is simply not practical for appraisals.
What FNMA and Freddie are really saying to appraisers is “appraise to the computerized review, rather than to generally accepted sound appraisal practices.”
ANYONE doing FNMA conforming loan limit appraisals for less than $650 is really devaluing their own time. Anyone doing the higher, presumably more complex Freddie Mac appraisals for less than $1,000 is a damn fool.
THAT is the real impact of CU or any of its counterparts.
Does anyone remember Robert McNamara’s whiz kids in the Kennedy Administration during the Vietnam War procurement fiasco for the M-16? The slide rules and computer whizzes decided that no cleaning kit was needed even thought they changed standard policy about having a chrome or nickel plated chamber AND they switched military rounds powder. The “science” proved how much better and cheaper it was.
The dead bodies from jammed early M-16s proved how wrong science was.
FNMA and Freddie have told us so specifically how we must appraise for there systems, that the results are no longer reliable; or appraisals feasible to produce without great increases in the amounts we charge the consumer for them.
I review complaints for AGA ( http://www.appraisersguild.org ) about CU on a weekly basis now. Complaints where appraisers have been unfairly steam rolled by improper application of CU; and or AQM. Now we can add Freddy to the mess.
ALL GSES really needed to do is to revert to FIRREA as it was originally written back in 1989. Before all the exceptions were carved out of it. FIELD REVIEW 10% of all appraisals and almost ALL problems will cease. When the odds are 1 in 10 of being caught, appraisers REALLY CLEAN UP their acts and don’t allow the kind of exceptions both FNMA and Freddy seem to be so concerned with.