Category: Illinois Department of Financial & Professional Regulation

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New Appraisal Assignment?

An appraiser receives an assignment involving a purchase contract on a short sale. The short sale price is $150,000. The appraiser concludes an opinion of value at $180,000. A week later the lender wants the appraiser to amend the appraisal to reflect the renegotiated contract that pegs the property at $180,000. As an aside, the lender would not provide the new contract. First, is the lender’s request automatically a new appraisal assignment? AO-3 offers useful guidance: Regardless of the nomenclature used, when a client seeks a more current value or analysis of a property that was the subject of a...

Caving in to CAIVRS 2

Caving in to CAIVRS…

As if the economy isn’t difficult enough, now appraisers are facing financial ruin through CAIVRS. CAIVRS is a Federal government database of delinquent Federal debtors that allows federal agencies to reduce the risk to federal loan and loan guarantee programs. CAIVRS alerts participating Federal lending agencies when an applicant for credit benefits, or for a position of trust in support of the administration of a Federal credit program, has a Federal lien, judgment or a Federal loan that is currently in default or foreclosure, or has had a claim paid by a reporting agency. In short, this is a database...

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Show and Tell

Everybody complains that the states aren’t doing enough to police the profession. Appraisers are running amok. Fraud is rampant and the states are twiddling their thumbs while caseloads grow exponentially. The handful of published state disciplines nationwide are a mere droplet compared to the vast ocean of chicanery that’s rising out there. Right? My question is, where are all the settled cases from the various professional standards and ethics committees of the big appraisal organizations? There should be a generous compendium of meaty disciplines somewhere. But there isn’t. If you go to their websites you’ll find plenty of references to...

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Picture This…Or Not

Maybe you should ask the homeowner if it would be alright to take the picture at all. When a consumer calls the department in a rage and wants to know “what law says that an appraiser can take pictures inside of my house?”, Houston, we have a problem. Actually, not Houston…and not the department. You, the appraiser and the client who ordered it have the problem because we will make it your problem. Law? There is no law for interior photos. There are guidelines and stipulations cloaked as requirements. That’s it. But, we do have privacy laws, don’t we? Clients,...

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CHASEing USPAP

Chase has turned a lot of appraisers into state appraisal boards. They’ve been responsible for nearly 20% of the Illinois caseload since 2008. The volume ebbs and flows from one quarter to the next. Not all of their complaints are good. Then again, not all of them are bad, either. All of their complaints insist that the original appraisal was too high. In their complaint submissions to us, they generally include a letter to the original appraiser that predates the complaint by months. In Chase’s complaints to us they typically include an appraisal review of some type. The standard review is a form 2000 as completed by an Illinois appraiser. Sometimes those reviews...

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UAD is Data Mining Nothing More

This article was published in the September 2011 issue of the IllinoisAppraiser Newsletter Blue Pill – Red Pill If you’re reading this on September 1st, you’re probably sitting in front of an unfamiliar drop-down menu on your appraisal software or frantically thumbing through Appendix D looking for an answer that isn’t there. Today is D-Day. Actually, UAD-Day. While Fannie Mae and Freddie Mac slide another deck chair over to catch a better view of the ice berg they’ve already hit three years ago, appraisers around the country are wrestling with Fannie & Freddie’s latest contribution to mind-numbing, muddled, mortgage malaise;...

Danger of 1004MC 2

Danger of 1004MC

1004MC : Danger! If you conduct appraisals for residential lending, you are familiar with the 1004MC. Many appraisers rely upon the data which populates the form for conclusions (e.g., trends for Property Values and Prices, relationship between Supply & Demand, etc.) which are later communicated on page 1 of a Fannie Mae appraisal report form. Of course, the data and analysis in the 1004MC are, in part, used by the appraiser in analysis in the Sales Comparison Approach. What could go wrong with this scenario? The correct answer is plenty, resulting in the appraiser communicating misleading opinions and conclusions. What...

Appraisers Assignment Conditions 3

Client Assignment Conditions & Appraisers

Client Kickbacks No, it’s not what you think. We’re talking about when a client kicks your report back to you because you did something wrong. Or did you? I was looking over a recent ServiceLink order that came in on a complaint. There were 32 requirements spelled out for the appraiser to follow. A four page order sheet with an 8 hour turn time for $200. Eerything was laid out from who could inspect to “your report must include photos of all 4 sides of the subject dwelling” (which is a cute trick for an inside rowhouse or townhome). Let’s...

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