How much vetting have you done on the appraisal management company? How involved are you as the lender in the day to day activities of the appraisal management company?… The world has changed and most everything in our lives involves technology. The technologies available to each of us are tools. They are not a more reliable means, merely more convenient. Human thought and analysis is still required in every aspect of life. When the Final Rules of the Dodd Frank Legislation went into effect, many lenders chose to use appraisal management companies with the false idea they had no liability for...
Our job is to observe and report. For an appraiser to arbitrarily go into another area to get “comps” merely because it would result in a higher value is an act of fraud… Dear President Biden, Sir, I welcome your incoming administration, and my sincerest hopes and well wishes are extended to you in terms of healing in this nation. Additionally, as an appraiser, I welcome the desire for equality in housing opportunity in the United States, and if there is any bias in my profession, I support efforts to correct this. However, in watching your party’s position on race...
The appraisal professions should be the only ones to determine any modernization; whatever that is… When Things Don’t Go as Expected Like so many others, I have learned the hard way not to accept any assignment without a little due diligent research first. Make no mistake I do not shy away from difficult assignments. I am under the firm belief the more difficult, the better. I actually enjoy the challenge. I recently accepted a private assignment over the phone for a lot in the City. I was driving and did not have access to MLS or locality records. I knew...
The FHFA is requesting input on appraisal related policies, practices and processes. We encourage everyone to submit comments. The Request for Input (RFI) is open to comment until February 26, 2021. The input received in response to the RFI will be used by FHFA to determine the necessary modifications needed to ensure Fannie Mae and Freddie Mac (the Enterprises) operate in a safe and sound manner. “Modernizing the appraisal process has the potential to create a more streamlined and accurate collateral valuation process. But if modernization is not properly adopted, it could have negative unintended consequences,” said Director Mark Calabria....
…gaming of the system is happening not only with income, (yes automated income verification has returned) but now property valuations… Appraisers have some very strong opinions on computer driven appraisals. Others are noticing the dangers as well. It is more than just automated valuation models though. In an article written by Danielle DiMartino Booth, for Bloomberg, Fannie Mae and Freddie Mac are specifically called out on their appraisal waivers. The author compares the dangers of the automated income verification being done in the 2000’s and how the system was easily gamed to the appraisal waivers currently being done. The author...
In 2018, the GSEs began working on ‘mortgage lending appraisal forms redesign’, a process they said would take approximately 3 years to accomplish. The effort is currently underway, however they have not announced exactly when the process will be completed, or when the new forms will take effect. Attached is a PDF of their FAQs through June 2020 which you may want to peruse, just so you become more aware of “what’s coming down the track” not too long from now. From my quick read of this FAQ document, key items include: GSE forms are not to be used for...
Appraisers, I had a recent discussion with a review appraiser, who discussed a ‘situation’ with me. It involved Highest and Best Use (H&BU), and the appraiser’s reluctance to re-do a report so that a loan could be made. The appraiser had checked the H&BU question box on page 1 of the 1004 form as “NO”, which immediately stops the lending process. This H&BU topic is sometimes difficult for appraisers due to many variables which need to be analyzed. The twisted part of this situation (which influenced the appraiser’s H&BU reporting) is the property is in an area where some, not all,...
On September 2, 2020, FNMA updated their policy allowing for Accessory Dwelling Units (ADU) on Single Family Residential (SFR) properties to be a Manufactured Home. This is in their Selling Guide Announcement SEL-2020-05, linked below. Key points: An accessory dwelling unit (ADU) is an additional living area that is independent of the primary property and has basic bathroom, cooking, and sleeping facilities. With this update, we clarified ADU property eligibility and comparable sales requirements in the appraisal as follows: expanded the current definition of an ADU to improve proper classification of ADUs; expanded property eligibility by allowing multi-width manufactured homes...
The continued reliance of unregulated aggregators and bifurcated products continues to erode the public trust at the expense of discarding the profession specifically intended to promote the public trust. How does this protect the public?… On June 14, 2005 Steve Jobs told a class of graduates, “you can’t connect the dots looking forward; you can only connect them looking backward” Around the same time, I was appointed as the sole residential member of the appraisal licensing board of my state. Little did I realize that this 2005 governor-appointed position would eventually lead me to sharing a stage in 2018 with...
Will this be detrimental to appraisal management companies that operate under the fast and cheap mentality?… Let’s face it, the appraisal management company will not survive with quality appraisals at a reasonable and fair fee… The Consumer Financial Protection Bureau is seeking public comments on the proposed rules for a Qualified Mortgage. The proposed rules require the lender to season the mortgage for 36 months before they can sell it to Fannie or Freddie. What that means is the lender will own that loan for 3 years. Fast forward if the new rule goes into effect… The lender will be...
