Property Data Reports for Appraisal Waivers
These Property Data Reports have a higher level or different reporting requirements than ordinary traditional appraisals.
Appraisers, on Tuesday 5/24/22, an AMC sent a message to their appraiser panel appraisers asking them if they’d like to ‘help their lender clients’ by doing Property Data Reports (PDR).
Let’s decipher what this is all about.
Freddie Mac has decided, that as of Sunday, July 17, 2022, they must have a PDR (Property Data Report) completed “by someone” in order for the loan applicant to qualify for an appraisal waiver in conjunction with a mortgage loan. In other words, actual qualified eyeballs must observe and report property aspects. Appraisers are included as qualified eyeballs.
Here’s the link to the Freddie Mac announcement.
To save you the trouble of reading the details, the key items are these:
- The Property Data Report (PDR) is a special ‘form’ developed by Freddie Mac which is primarily composed of “checkbox” entries organized into related sections of property characteristics, with a few free-form comment sections
- The process to provide the PDR includes having the ‘observer’ prepare and include a FLOOR PLAN diagram of the dwelling, not requiring the ANSI measuring protocol. That must include exterior wall dimensions, interior wall placements, doors, and room labels. This is a ‘higher level’ diagram than just a dketch – which is what is included with a traditional 1004, etc., report.
- Specified photos of the property, etc., must be included, taken by the ‘observer’, but one item is new: those photos MUST have a date stamp on them generated by the camera
- There is NO value stated on the PDR because this is NOT an appraisal
As you can see, these Property Data Reports have a higher level or different reporting requirements than ordinary traditional appraisals.
The other item I’m not sure about, yet, is whether this new Property Data Report ‘form’ will be included in our report software from the multiple vendors. I just checked my software and the PDR is not in the forms package now. So that means you may have to ‘hard copy print’ a PDR form, take it into the field, and use a pen to input the checks and written info. Back at the office you’d have to scan it to a PDF, include photo page(s) and the FLOOR PLAN, and submit that report bundle back to the client. This is going to be a bit cumbersome to start.
AMC’s who will be requesting appraisers to do these Property Data Reports are also seeking “what your fee will be.” This becomes a bit tricky, because all homes are different in their designs. A rectangle will take much less time to measure and do a FLOOR PLAN diagram than a multi-story tract or custom home. So the appraiser MUST do advance research on the home before quoting a fee, at least initially.
Even though this product is NOT an appraisal, it is to be used in conjunction with a mortgage loan. Therefore, the lender must reveal to the borrower what anticipated costs will be. Once those costs are stated, it is very difficult for the lender to backtrack and re-state the Property Data Report fee to the borrower if the appraiser does not quote the fee properly up front. So be real careful with this!
Some appraisers have already indicated that they WON’T do the new Desktop and Hybrid report assignments. From what I’ve seen, that is primarily due to the reluctance of accepting other ‘observers’ data.
But these new Property Data reports DO include the appraiser – if the appraiser chooses to do these. It’s a way to stay employed, especially during the current slow assignment period we’re experiencing.
Dave Towne on e-AppraisersDirectory.com
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I have an Apprentice that is 4 months in and has done 50+ inspections with me. I might feel comfortable with him doing these on his own in a couple more months. Would be good training.
It’s like asking a Doctor to take on CNA duties so the patient doesn’t need a Doctor and pay him CNA wages (unless you can charge full appraisal fee for the PDR). Silliness.
CAN YOU SAY “COLLATERAL VERIFICATION”?? Appraisals as we have known them include both a value and collateral verification. Someone within FANNIE had decided to separate the tasks believing that investors will accept 3rd party unlicensed and unsupervised building inspectors to verify the collateral. The financial world would be foolish to believe that AVMs within this scheme provides an accurate determination of collateral risk. No matter how they wrap this foolishness, it is destined to fail. The real secondary mortgage market (not in conservatorship) will reject this foolishness. Intelligent responses welcome!!!
Watch for Lyle Radke as the FANNIE spokesperson promoting the benefits of the two tier system – a good read, but a believer in AVMs as the future!!!
I wonder, what will the E&O providers have to say. A number of years back I was notified by an E & O provider that if an appraiser does a sketch for a real estate agent that was not part of an appraisal it is not considered an appraisal activity and is therefore not covered by the E&O policy. If a law suite took place regarding the sketch you were on your own.
A licensed Appraiser has to charge for the liability not the time, charging by the hour is foolish when the client threatens your net worth, and future.
On a side note, Target & Walmart are now paying $22.50/hour for starting wages where I live.
Why go to all that trouble and delay? Why not order an appraisal?
Exactly, quite right. You know we used to call the service PIR’s, we filled them on FNMA form 2075. Appraisers were routinely paid $150-$250 or more per each one. And all lenders ordered them. It was how many an appraiser was able to train new hires, and is yet another example of the destructive force of amc’s, the way they also brought in realty agents to complete variety hybrid and other alternative products, raked off the top, charged more and paid less. Appraisers cumulatively lost billions on the loss of that product alone.
Read the guidelines for this product. Appraisers are providing an appraisal service, you have to give a qc rating deal. How they think anyone other than an appraiser can comprehend and comply with these programs boggles the mind. And what planet are they from, to think that a date stamp will in any way inhibit the data scraping and copying fraud which is about to occur. Toss a date stamp on anything at anytime, it’s not hard. Nobody is going to be asking what model camera people have to verify if the stamp is appropriately generated, they will not have a clue and many an ‘inspector’ will forget in the field, photoshop that in later. Did you read the wells fargo story about all the high level mortgage people firings over abuse of waiver systems, changing internal value indicators, happened just the other month. Oh yeah, appraisal waivers are such an easy to navigate program. And….. Immediately abused by lenders. Who could have ever predicted that?
Newsflash, these are not temporary things to get appraisers by until things come back. The mortgage lending industry is in freefall and layoffs continue. The mb’s whom are left, getting strategic and such. Just got invited to a free luncheon deal meet and greet. You know how it starts right; free lunch just to get bodies into the door. Because there are not enough customers to support even the remaining minimized staff. I’ll be like, ah, free turkey sandwich if I refinance, oh hell, why not, give it to me I’m hungry now. Where do I sign?
Also like the comment about liability. Think about it, many here would never complete a final inspection report for someone elses primary appraisal. It means we’re signing off on and accepting their value conclusion. And what, do you think providing supporting services for an avm figure will be any different? You’d better get detailed information from your insurer to see where coverage and liability rests. Because you’ll be signing a lot more of these ‘reports’. If these come through an amc you may want to insist they provide a liability disclaimer which shields the appraiser. And what is ‘an appraisal’? Do you need to have provided a value opinion to have provided ‘an appraisal’? You’re certainly providing some form of appraisal service or valuation service if you start going to properties, providing sketches, filling forms and checking boxes, free filling market data, perhaps signing. This amc industry, keeps getting better all the time. Half the work will be for pre foreclosure or loan restructure analysis. Dreaming of better days.
I do not see any reference in the Certification of Completion section of the 1004D to the value in the original appraisal. The only reference is to the “requirements or conditions” ie. repairs. Maybe Baggins is confusing the 1004D with a review appraisal.
Perhaps I should have phrased that as a question. Is this product ‘an appraisal’? And I just presumed we were providing ‘appraisal services’. Author Dave seems clear if I’m interpreting accurately, he is associating the end point of value with the act of providing ‘an appraisal’, saying it’s not an appraisal. It was my understanding that an appraisal does not necessarily need an end point value opinion, and that providing any part from the full range of valuation services constitutes appraisal services in general. Oh, er, you’d always have the appraiser hat on with these products. Oh this is where the details get tedious. Your take on that? I mean even if as blog poster David states, they’re uncoupling collateral verification duties, has that uncoupled the appraisers liability exposure? This is why I just have pursued only full fee full order work for this long and can’t bring myself to even try these products. No matter what burden I’m relieved of with single orders these puppies still back up a complete full mortgage package.
Don I forgot to mention the longstanding argument of document incorporation ‘by reference’ or ‘by attachment’. The documents are incorporated naturally so there is no need to reiterate that in certifications on form. Never had clear answers to this over more than a decade but remember reading about these legal principals. 1004d runs congruent as by attachment to the 1004 form, and by reference to the loan package in general. The 1004d regardless of which box is checked, is never a stand alone document. Thereby causing situation of shared liability. It’s all over my head and would not want to get caught up with that. Additionally without providing some review service and reading the initial report, it can be difficult to know if the value stated was hypothetical as if repaired, or was as is and these were minimum property requirements, etc. It all falls apart when you ask for one more or one less repair item than the other guy called. It never works.
Like that should be a game changer for anyone whom orders appraisal services; if the appraiser can not be available for the final, they should just order another full from someone else and drop that appraiser from the panel. I’ve seen lenders use finals from secondary appraisers as ways to over ride valid safety concern and inspection requests. It’s like being a back pocket appraiser, hard pass.
This industry has been running fast and loose for more than a decade now, too cozy with reduced service requests, outsourced services, third party help. If the market slides back many an appraiser will get an after the fact lesson that they were producing legally binding documents this whole time with no other choice but to stand by their own signature. Which is why if I’m even slightly confused about anything, pass on the request. A third party inspector whom I don’t get to know who that is how they were hired how much they were paid and I rely on their data for my signature? You don’t say. Next. An appraisal that is not an appraisal with no value but I still meet the borrower and do all these routine appraisal tasks? Like I’m the face and personal representative of their AVM efforts of which I have no influence and no control? Pass. A hybrid report where I supposedly do so much less it takes a tenth the time but in the end, still provide a valid market value figure and shoulder the same business costs and liability exposure? Curious. Next. Remote appraisal services where you don’t even need to show up? Hey, I think there is a pattern developing here… For the last decade we’ve only dealt with state boards and occasional insurance claims primarily. That could change soon.
https://www.lawinsider.com/clause/incorporation-by-reference
Baggies mentions Wells Fargo. I read the article. Did they get arrested for mortgage fraud? Did Wells lose their Mortgage privileges? How about the uppers the fired folks referred too? Did they reopen all of those files and order the appropriate collateral verification? Where are the lawmakers now?
Another duplicate post. Sorry about that, edit away, see below.
To the best of my knowledge, the 2075 form does not constitute an appraisal service since no value, direction of value or range of value is indicated. That, in my opinion is why a 1004D Update is an appraisal and a 1004D Completion report is not. The Update Report is a direction of value and a Completion Report is a status or repairs statement.
Baggins – You are only liable for what you do; not for what you do not do, unless of course you agreed to do something and did not do it. That is call “Scope of Services”. I agree it is not that simple because rarely do the parties really agree on scope of services (ie. obscure vender agreements, small print or not reading the scope thoroughly, but in a perfect world………
That’s interesting, thank you David. Only liable for what you do…
https://guide.freddiemac.com/app/guide/bulletin/2022-6
Lets dig into it. What exactly are we doing if we complete these? A quote from Daves source links.
“When the ACE+ PDR option is accepted and a PDR has been used to originate the Mortgage, Freddie Mac will accept the estimated value submitted by the Seller for the purposes of underwriting the Mortgage, and will not exercise its remedies, including the issuance of repurchase requests, in connection with a breach of the Seller’s selling representations and warranties related to value only.” (emphasis on the related to value only part, which they bolded in the faq guidance.)
So they’re only decoupling liability for the value part? There is such a long list of requirements the inspector must meet though;
“The property data collector training curriculum must include, but is not limited to, the following topics:”
It’s such a long list, and what if someone disputes your quality rating, adverse site conditions opinion, finds a minor error in your sketch? If an appraiser did that we’d be providing appraisal services. I read through the entire thing again, it’s sort of ambiguous on the points appraisers want to know about.
I’m drawn to AO-2 & the reference to AO-23 on this matter. We’re talking standards rules for personal inspection, competent data gathering, and completing an actual ‘assignment’ with defined scope of work. We may not be providing the technical definition of an appraisal but would appear to still be providing property characteristics by which the avm value is qualified. That’s an appraisal, or at least the better part of an appraisal. Even if it does not have a value number attached, that’s providing appraisal services. The guidance faq makes it clear, they’ll only relieve the representations and warranties for the avm value. That infers the full weight of liability for all other services provided may still be present based on characteristic reporting and the liability exposure could be tied to the homes worth. I would want a special scope of work agreement there reiterating the lender accepts all liability. How would the state consider this if let’s just pick out a random example, someone whom used to be an appraiser but lost their license was completing these reports? If it’s not an appraisal, and we’re not providing value services, is the position there that the state would not be allowed to investigate complaints against appraisers for these specific work products? Can you imagine that? Of course they would investigate, of course of course of course. Because we’re providing services supportive to a valuation process. Being demoted and not trusted with a value opinion did not stop us from being appraisers, providing data utilized for valuation and property characteristic services. I can’t get over the aspect that if appraisers accept these, they’ve basically accepted a demotion. Can I have my broke ass cousin non-appraiser sign all the reports to protect my liability?
Per the TAF voluntary disciplinary action matrix, boy that’s complicated to imagine what penalty the appraiser might face for these. Let me first ask a specific question; Do appraisers need to keep a workfile if they have completed this task? Because if you have to keep a workfile, it’s an appraisal right? I don’t get it, where the appraisers liability exposure is, and where the appraisal services duties end with these products. It’s everything we’d normally do in the course of providing value services, just less the portion where we do MLS research and place an actual number there. And you know home inspectors are going to be abuzz about this work product too. That’s awesome, appraisers are going to fare real well competing with every realty and inspection agent for reduced pay working assignments.
I’m not so sure and am not optimistic about the direction this is taking. There has been so much effort to reign in an unruly mortgage lending industry and as soon as something settles down, they just reach for another work around to gain even more leverage. I’m not buying into the supposed legitimacy of these avm integrated and reduced appraisal service terms sort of requirements. There is absolutely nothing comparable to reviewing a home in person and selecting the comps yourself. What would you do if you were privy to the avm opinions furnished and knew for a fact they were much too high or too low compared to what you would have provided? How would you handle the upset call from a borrower? You were ‘the appraiser’ whom showed up at their house right? Now we’ll all sound like con artists; ‘Yes we’re appraisers, but we did not actually provide an appraisal.’ If I was the consumer I’d be like you’re kidding me, then why the hell did an appraiser come over for my mortgage loan request? The assumption for undervalue avm would naturally be the appraiser provided some sort of material reporting error which led to that. Yeah, the more I think about it, the more I don’t like these.
Flash from the past. We used to post this a decade ago. Apparently whomever runs this site has updated the list. It’s the top google hit if you search mortgage lending layoff, at least it was for me. Something is happening.
https://www.thetruthaboutmortgage.com/a-list-of-recent-mortgage-closures-mergers-and-layoffs/
https://nationalmortgageprofessional.com/news/wells-fargo-fires-loan-officers-accused-abusing-appraisal-waivers
https://appraisersforum.com/forums/threads/fraud-in-appraisal-waiver-programs-who-could-have-predicted-that.232608/#post-3165632
Detailed wells waiver story. Don’t worry, they handled it themselves in house. Nothing to see here. So if they devalued the avm to qualify for the waiver point, which is under 1m, does that mean they originated a conventional when it should have been a conventional jumbo? Did I use the term correctly? Quote from article below. As one of those appraisal orgs also signal a move to develop a new rule set which will ‘certify an avm’. The waiver was clearly a mistake. Relying on an avm is clearly a mistake. Raising demins was clearly a mistake. Holding rates down this long to fuel an accelerated housing market was clearly a mistake. Embracing ibuyers as legitimate participators whom did no harm was clearly wrong, a major major major mistake and they’ve disrupted our entire residential housing market within the first few years.
You know what nobody is talking about; How all of these mortgage lending allowances benefited ibuyers and corporate rental companies, and in turn drove all our housing prices up nationally to the point many many persons are now elbowed out of the housing market. Yet somehow these avm and ibuyer companies are on advisory boards for PAVE and FAIR. They’re pointing fingers desperately at appraisers, using their incorporated corporate fake news media mechanism to get there. The reason seems obvious, they got caught manipulating the entire American housing system and it did not play out how they anticipated. There is no such thing as a residential housing market anymore, it’s all commercial. So racist appraisers are probably at fault for all the commercial failures too. Anyone care to explain how appraiser racism is not a concern in commercial markets? There should be ibuyer prohibitions put in place immediately and commercial rental could be restricted by removing taxation relief benefits specifically for detached single family housing and small scale attached. We can’t compete with global corporations to buy singular homes and singular land lots, yet that is the new reality. Nobody to date that I’ve heard of has analyzed how much ibuyers cumulative participation efforts into residential housing over the past 3 years may have effected rising pricing and increasing scarcity, but I imagine this could be substantial like into the fifth or even third of total housing ‘value’ today.
And that’s just one side of it, ibuyers are not the only players. Corporate interests are fleecing manufactured home parks left and right, no end in sight. It’s going to build to a similar situation for everyone else soon too, that market is just about fully exploited. You see when actual commercial markets tanked, these companies simply took a side step over to ‘residential’. I talked to an electrician dude from boulder whom ‘just bought something’, so they got into land lease manufactured. Not but a year after buying a corporate entity bought the lots, there was no co opt land purchase effort mounted, and their lot leases doubled up to I think he said $900 a month. Related articles after this quote from the above link. ///// Quote begin.
The Appraisal Institute previously expressed concern for increased use of appraisal waivers after the pandemic began. The 2021 Appraisal Institute President Rodman Schley, said, “These waiver programs will create unnecessary and unacceptable risks for taxpayers, and risk mitigation should be paramount. Reducing appraisal requirements sends the wrong signal to mortgage loan sellers about the importance of fundamental risk management practices.”
Today, the Appraisal Institute raised concern once again. “As the only objective third party in a real estate home sale or refinancing transaction, appraisers are uniquely positioned to generate credible, reliable opinions of value,” said Jody Bishop, president of the Appraisal Institute. “The recent revelations of lenders using arbitrary valuation estimates raise legitimate concerns about the oversight of appraisal waiver policies. Current market conditions, with rising interest rates after years of rapid price increases, clearly highlight the need for enhanced due diligence in the mortgage market to ensure property owners, borrowers, lenders and taxpayers are protected from loan fraud.”
The Appraisal Foundation has denied a request for comment on the matter. //// Quote end.
These links; The ongoing saga of corporate buy outs of manufactured home parks. Colorado specific but I’d bet it’s happening in your state too. Things to be aware of if you deal with land lease manufactured.
https://www.cpr.org/2021/11/04/colorado-mobile-home-communities-affordable-housing/
https://apnews.com/article/business-lifestyle-colorado-618b9fb2ba93e13b651d6e51d408a7e2
https://www.denverpost.com/2021/10/10/colorado-mobile-home-parks-resident-owned-communities/
Keyword research string (just sub your state in this search) manufactured homes corporate buyers colorado co op.
Appraisers can ONLY defend the work they have submitted, rwrighting is the rule in real estate.
The lenders, the underwriters, the brokers, the agents, the attorneys, the Bonding underwriters, etc. have to defend what they dooo. If you sign it, you defend it, as long as its an appraisal. The investors are on the hook for all the side interpretations. Is your E&O insurance good for any thing other than appraisals, were you part of some crooked scheme, or just a dumb assed interpretation
Keep it simple then? I’m using Landy, never had a claim. They told me I’ve got drone coverage now too, o.k. Are the above mentioned products appraisals or are they not? Would we even need to keep a workfile? Is there liability exposure? Why can’t these lender people just go with effective programs and continue ordering full appraisal products delivered entirely by qualified human appraisers?
Sued in both criminal, civil, County, State, and Federal Courts, chose my defense from community knowledge and experience. Know this! your insurance company can negotiate your reputation away.
Once I was sued as a co-conspirator in fraud and my client was A County Board of Supervisors, I chose a private group of attorneys and we all won. In another my client was a dope defender, sold a P.I. case to another attorney and didn’t report the case to the IRS. The rules are different for federal criminal courts, had to lien the job and didn’t get paid till my client got out of jail, a year later.
Disconcerting to think of the costs of that vs this easily replaceable minimal income…
That settles it. I’m buying the lawn mower.
I’m in Florida. Those lawn mowing people don’t look so happy in August down here. Tons of rain and very hot and humid. Besides our real estate values are out of control. Just FYI in case your picking your “retirement” gig.
Thanks Bryan. The lawn mowing reference is like my running shtick. Symbolic of something better. I’ve actually done that before when I was younger. I don’t know though, I ran across a city guy doing just that last month, getting nearly $30 an hour to ride a lawn mower all day. It’s not like maximizing my potential but times are changing, apparently parks work is paying well these days. I’ll be like supervisor of the parks staff or something, who knows. Somethings got to give soon, with a strict focus on mortgage lending and/or default mangement, I’m in still waters lately. Thankfully the rapid new construction development really slowed down, so there is an upside to slower moving markets. And there are often only singular offers so there is elbow room again to get out there and try to land something you actually want. This 10 offers and 100k over program was untenable, like we’re not going to compete in that climate. We hope the rates stay high for some time to come and eventually the market will adjust. It’s just going to take time for people to accept the new realities.
What’s supposed to be happening right now in a cyclical real estate market is a transition to some reo default management and a sequence of loan modification and pmi removal work. We’re just not getting that anymore. The amc fee raking was just the tip of the iceberg for how much these companies stole from the appraisal industry to put in their own pockets. Amc’s are the primary root cause for the lack of new trainees as well as coverage issues. 3 out of 4 licensed appraisers won’t even work with these companies. Literally half of all appraisers out there abandoned mortgage lending work due to amc influence.
I’m in it because of the love of helping people, getting out there, freedom of time, seeing new places. If I am to be tied to the desk with desktop, I want benefits, legitimate retirement, employment, paid days off. It’s something the GSE people consistently refuse to acknowledge. They just cop out and say amc’s are not under their jurisdiction. Billing however is under their jurisdiction and the GSE’s could demand separated billing practices. The GSE’s could demand only appraisers complete any and all valuation service actions.
Appraisal valuation services is where all too many companies carved out a work around to institute the same old junk fee, bill padding, and outsourced services practices which were made to be prohibited in so many other spaces. Amc’s came after that fact. And now that it’s so profitable to do so, like the old days of free for all lending, they want to expand the operable space for such practices.
They want in. We want out. It really is that simple. Comprehensive reform potential is long since in place, but someone out there will need the fortitude to hold amc’s to the same standards they held everyone else to for that reform to happen.
I’d better check my lotto cards and pray for a miracle, I’m going to need it. Is anyone here perhaps selling a ride on mower at a discount? I’ll drive it home on the highway if that’s what it takes.
What do you think about this potential marketing strategy;
Value services; now with free lawn mowing! This could work. I’m going to put together a flyer. Imagine me on a ride along, with a clip board, camera, tape measure, long piece of grass out my mouth and a country hat in a button up shirt. Out there taking legitimate comp pics. I’ll fit in the mowing while I’m measuring. I’m trying to get the most out of these last days. Have mower, will travel. Dude, send me an order all ready, come on. So much for tenure.
Well another issue – all of the lawn mowers are manufactured in one place! Come on – guess where. I like the cross selling though. I might add bug spray in there for an extra 10er!
Naaaa. I’m getting a very very special mower. Like supernatural awesome, life changing. And I’m spending more time on lawn mowing forums. They’re way better. People actually like their jobs and respect the other people they work with in the lawn industry. They’re not surrounded by opportunistic crooks trying to rip everyone off.
Joel from a la mode, here. We’re working on a solution for PDRs and should have it out next month when the PDR program starts.
We’ll have more information coming very soon.
Multiple companies near my office are chaging (and getting all week long) a minimum of $200 for a basic floorplan sketch up to aroun $400 for a more complex 2 or 3 story home in the 3,000 sf to 6,000 sf range.
That should save time and money!
Are they required to work with amc’s to receive the work?
What were consumers charged for the service?
And please be specific, if those are licensed appraisal companies or not.
Desktops do away with collateral verification. AMC hires certified general appraiser. AMC and certified general appraiser apply for and get a license in your state under reciprocity. Start doing desktopmappraisals at below market fees. And to add insult to injury attempt to hire a bunch of trainees in your state to dimiinish business share – what do you think of that? Collateral verification may no longer be an appraisal issue.
I think it’s a plot to get rid of the collateral verification a handoff to third parties. All the more reason why we should not cooperate with the desktops. Look what it’s done to use USPAP makes no sense.