Category: USPAP

Appraisers Should Never Do Evaluations - Appraisers Blogs 15

Appraisers Should Never Do Evaluations

…users of evaluations knew & accepted that if they obtained evaluations in lieu of real appraisals that they were getting meaningless value opinions by unqualified personnel… TALCB will be considering the Board’s position regarding appraisers performing evaluations in compliance with USPAP at the next Board meeting on August 23, 2019 Dear Texas Appraisers Licensing & Certification Board Members: The short and sweet version is that appraisers should never, repeat never do ‘evaluations’. The term itself should never be uttered as if it refers to any legitimate appraisal product that meets the USPAP requirements of a real estate appraisal. When FIRREA...

Bifurcated Appraisal Fans Can Claim SOW Till They're Blue in the Face 50

Hybrids vs USPAP Scope of Work Rule

Supporters of the bifurcated appraisal can claim scope of work till they are blue in the face… Appraisal Buzz published an article written by Joshua Walit on July 31, 2019 titled Nothing New Under the Sun: The Varied Face of Appraisal. The article brings up some good points, however; it does not take into account the reality of the market and the control of the lenders and appraisal management companies in the process. The mere fact that the appraiser does not have control over the person completing the inspection and in most cases, no way to even know who is providing the...

Holding AMCs Responsible for Hybrid Inspections - AppraisersBlogs 11

AMCs Responsible for the Hybrid Inspection

It seems holding the appraisal management companies responsible for the hybrid inspection is the best option. The thinking was they choose, engage and pay the inspector. The Virginia Real Estate Appraiser Board met for its quarterly meeting on July 30, 2019. We are happy to report CoesterVMS no longer has a license to operate in Virginia. The Board voted to accept the consent order accepting the voluntary surrender of his license. The Board also passed a motion to draft legislation to be introduced into the General Assembly giving the Board regulatory control over the hybrid inspection and those individuals that...

Existing Regulatory Burden on Appraisal, a Proven Failure- System Reform 6

Appraisal Reform or System Reform

It is my hope that the Subcommittee on Housing, Community Development and Insurance consider long-term impact. The existing regulatory burden, a proven failure, may insure a repeat of the past. The body of a letter to the U.S. House Committee on Financial Services about systems reform. Appraisal reform or Appraisal industry reform? It is critical to understand that ‘appraisal’ does not equal ‘valuation’, or risk analysis, or anything else.  It is a precise definition of a nebulous product. The current U.S. House Committee on Financial Services is asking the question: “What’s Your Home Worth? A Review of the Appraisal Industry.” I believe it is...

North Dakota Appraisal Waiver Granted 8

North Dakota Appraisal Waiver Granted

News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...

Coester Risen from Ashes? - Homeowners to Provide Data for Evaluation 26

Coester Risen from Ashes?

Has Coester risen from the ashes? Apparently, per a message on Twitter on July 9, 2019, Mr. Brian Coester is now in the real estate sales biz. The photo image used on the big T is the same one he used to use on his defunct AMC website. More information here for re-posts of articles not written by him. Meanwhile, there appears to be a new twist in Evaluation appraisals. This is the first I’ve seen about an AMC or any other company using ‘the homeowner’ to supply interior photos which will be used in a bank evaluation. See this...

Review Appraiser Flawed Review... Phony Complaint Against Appraiser 14

Phony Complaint Against Appraiser

…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...

Clear Capital Admitting Hybrid Inspectors Are Offering Appraisal Opinions 34

Hybrid Inspectors Offering Appraisal Opinions

Clear Capital admission: This is an admission that inspector were previously offering appraisal opinions re Q&C. There remain many other areas in hybrids that also are appraisal opinion being provided by non appraisers. I have written many blog posts here, mainly for the consumer to read and understand what is actually happening in the world of Real Estate Valuations. My blogs range from being overcharged for appraisals so the middle man (the appraisal management company or AMC) can make money, lenders still pressuring appraisers to hit a value, and now having untrained and unlicensed people perform inspections (see my last...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. https://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Bifurcated Appraisals, a Controversial Topic - Call to Action! 5

Bifurcated Appraisals, a Controversial Topic

As most of you know, hybrid or bifurcated appraisals are a very controversial topic currently. Virginia statutes and regulations have language which gives many of us pause on the compliance of hybrid appraisals as they are being presented in the industry. The Board has published a proposed guidance document in the hopes to clarify the language in our laws. Unfortunately, the proposed guidance document falls short of providing any meaningful guidance or clarification. Per Virginia statute, the document has been published on Virginia Legislative Town Hall for public comments. At the end of the comment period, it is our understanding...

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