Banks Are Driving the Waiver Train

Banks Are Driving the Waiver Train - Appraisers BlogsOn its own, the recent decision to provide a temporary appraisal waiver for the entire state of North Dakota is mind-boggling for a number of reasons and seemed pre-determined:

  • The state has been challenged by the lack of appraisers in rural areas since time began and there are plenty of appraisers in metro areas.
  • The inference is that all states with a lot of rural areas should have to have qualified experts come up with valuations.
  • There is no verifiable appraisal shortage in the state. In most cases the problem is with AMCs and their business model, unable to pay a fair wage to appraisers covering rural areas.

Look at the ASC members and their North Dakota waiver vote on July 9, 2019


  • FRB – Art Lindo (Chair)
  • CFPB – Philip Neary
  • FDIC – Marianne Hatheway
  • NCUA – Tim Segerson
  • OCC – Richard Taft


  • FHFA – Robert Witt
  • HUD – Bobbi Borland

Only FHFA and HUD voted against the North Dakota Waiver. Those specific agencies deal with appraisers first-hand and understand their role in the risk management process. The remainder are bank regulators or in the case of CFPD, represent consumer interests (and the agency has been gutted over the past several years to reduce its pro-consumer efforts).

In other words, banks are driving the waiver train. They want to remove a pain point from the mortgage process to grow more origination volume. The Federal government has already proved it will be willing to back up the banks if the economy collapses so why not keep pushing for removing of all pain points?

Jonathan Miller
Image credit flickr - Schnitzel_bank
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

You may also like...

15 Responses

  1. Kimberly Pugh DeFilippis on Facebook Kimberly Pugh DeFilippis on Facebook says:

    asshats, the lot of them.

  2. Donna Corrado on Facebook Donna Corrado on Facebook says:

    We will be appraising REO’s in the future

    • Avatar Koma says:

      We all know that history repeats and they never learn due to having no real consequences. I feel another tax payer bailout coming up. Oh for those who don’t know..ahem..banks: bailout, noun, an act of giving financial assistance to a failing business or economy to save it from collapse. Man the American public needs to jack any politician (don’t care which party) that makes a bailout happen again. We all felt the pain except the big banks felt what maybe a pinch if at all.

    • Avatar don says:

      We’ve done it before and we can do it again, Ain’t that a cheerleaders cheer. By the way what is slow paying AMC are they related to money in front?

  3. Scott Dibiasio on Facebook Scott Dibiasio on Facebook says:

    The residential side of this waiver will sunset 60 days from today – the effective date of the increase in the residential de minimis to $400,000. At that time, the appraiser waiver will only be in effect for CRE transactions between $500,000 (the current CRE de minimis) and $1,000,000. The CRE waiver will terminate on 8/7/2020, unless further extended by the ASC.

    • Good points for us all to remember.

      Frankly, the trend is to seek residential waivers because it normally would apply to all transactions, but in this instance, even ASC put limits on the waiver issued. So, the ‘get it for residential and then use it for CRE’ scenario is not as onerous as would be expected otherwise.

      A lot of damage can be done in 10 months. Especially in small commercial-agricultural properties.

  4. ronnyr on Twitter ronnyr on Twitter says:

    The will still charge the customer for a computer model and snap shots call it an appraisal…like everything else in this country dumbed down for corp profits….ride her till she bucks you

  5. Avatar David says:

    What do you suppose they were talking about recently in Vegas – “How to put the breaks on rising appraisal fees”. Remember dear friends – they’re sweet paper has no value without collateral verification. We are the only licensed entity to provide that. We are the only eyes in the field. Anything else becomes “B & C” paper. Much higher risk to prudent investors.

  6. Avatar Cotton Cornell says:

    As we are all fully aware fannie mae and the other GSEs employ a lot of people who have their appraisal license however very few of them have any real field experience. This clearly has caused a problem with our profession as there are entirely to many non appraisers or appraisers who have no real appraisal experience determining whats best for the appraisal profession. Those appraisers who are in chief appraiser positions working for lenders and amcs are forced to promote false narratives and promote scam bifurcation appraisals in order to keep their job and make the corporate managers happy. All of this stupidity has resulted in a broken appraisal system. Time is now to push back. Say no to low fees, no to harming public trust, no to aiding the amcs to the destruction of our business. As we have seen with the service link fee list we have been scammed for way too long! The smallest part you play in changing this profession could have the largest impact. Push back on everything you know is wrong! Have a blessed day!

  7. Avatar David says:

    Cotton – well put – I totally agree – fee push back is the way to go. However, I would remark don’t waste time on what is “right” or “wrong” – learn to bracket your comps, include listings as that speaks to NOW and alternate choices; and discuss each comp as to how it is relevant – few do! Stop pretending you are a lawyer, home inspector, permit expert and architect. Gert it done.

    • Avatar Residcert says:

      Experienced Professionals familiar with the Appraisal processes should be able to look at the grid alone and recognize whether correct bracketing was used. The problems we face are former retail sales people making minimum wage or someone from India reviewing reports


Leave a Reply

We welcome critical posts & opposing points of view. We value robust & civil discourse. You may openly disagree, but state your case in an atmosphere of mutual respect, in which everyone has a right to a particular view about the topic of conversation. Please keep remarks about the topic at hand, & PLEASE avoid personal attacks. If the poster gets you upset, it is the Internet, you can walk away from it.

Personal attacks harm the collegial atmosphere we encourage on AppraisersBlogs.

Your email address will not be published. Required fields are marked *

xml sitemap

Banks Are Driving the Waiver Train

by Jonathan Miller time to read: 1 min