Category: HUD

Uncovering Flaws in FHA Appraisal & Loan Review Process 21

Uncovering Flaws in FHA Appraisal & Loan Review Process

The story of this single mother’s harrowing experience with a defective home purchase and HUD’s negligent oversight exposes deep flaws in the FHA appraisal and loan review process. After sacrificing for years to rebuild her credit and earn the right to become a homeowner, this borrower found her dream home in the country – or so she thought. During the home inspection, several issues were flagged. The seller, an investor who had purchased the home in an estate sale, was unaware of the system’s location. The seller agreed to have the tanks pumped so the location could be determined. By...

Unresolved Complaints Filed with HUD 47

Unresolved Complaints Filed with HUD

The “unresolved complaints” may not be as clear-cut cases of discrimination as they are being portrayed. The lack of resolution in the fair housing complaints filed with HUD regarding alleged appraisal discrimination has become a pressing concern for all parties involved. As highlighted by Peter Christensen, HUD has received over 200 such complaints since 2020, yet has failed to make a determination on the merits of any of them, either way. This suggests that the complaints are not as straightforward as they may initially appear, and that there are significant challenges in distinguishing legitimate grievances from those driven by other...

Low Value = Material Deficiencies? New HUD ROV Policy 39

Low Value = Material Deficiencies? New FHA ROV Policy

The implication that if the VALUE is too low, then there must be “material deficiencies” present, is deeply troubling!  Up until recently, there has never been a standardized policy for mortgage loan related Reconsideration of Value (ROV) requests after an appraisal has been submitted. Now there is, per the attached PDF HUD/FHA mortgage letter. The GSE’s have similar policies. I’m not opposed to having a standardized ROV policy. However, these policies are in keeping with the new initiatives surrounding alleged and often unproved appraisal bias and discrimination claims. But when one reads deeper into the reason for implementing these procedures,...

Ken Mullinix Has Become a Figure From a Kafka Novel 7

At Federal Agency, The Mayhem Is the Message

Mullinix has become a student of the “Title VIII Complaint Intake, Investigation, and Conciliation Handbook (8024.1).” The handbook is designed to protect citizens from overzealous federal workers. He found section after section had been violated in his own investigation by the HUD contractor.  Czech-German author Franz Kafka wrote “The Trial” in 1915. The novel is a reflection on bureaucracy, power and absurdity. Its protagonist, Josef, is arrested and prosecuted by a mysterious and inaccessible authority for a crime that is never revealed to him or the reader. It’s a man’s journey through an incomprehensible and dehumanizing landscape. Ken Mullinix has...

Marcia Fudge Leaving HUD Is Good News for Appraisers 38

Marcia Fudge leaving HUD!

Marcia Fudge is also the current co-chairperson of the PAVE Task Force Committee, so that group’s philosophy may also be modified with her resignation.  I read a number of web provided publications oriented to our appraisal work, and lending. This popped into my email yesterday from Inside Mortgage Finance Publications: “As IMFnews went to press Monday, Marcia Fudge announced that she will step down as secretary of the Department of Housing and Urban Development, effective March 22. A Biden appointee, Fudge, 71, did not provide a specific reason…” USA Today: “Fudge vows not to run again “Don’t look for me...

Is the GSEs "Appraisal Modernization" Really Just Mass Appraisal? 18

Is the GSE’s “Appraisal Modernization” Really Just Mass Appraisal?

Mass Appraisal tend to exhibit a regressive nature…  In the intricate landscape of real estate mortgage financing, the notion of appraisal waivers recently dubbed “Value Acceptance”, by the Government Sponsored Enterprises (GSEs), has stirred considerable debate. The most recent statistics show Value Acceptance accounts for up to 40% of all mortgage approvals. It is presented as part of the GSEs “Appraisal Modernization” initiative, which aims to streamline the mortgage appraisal process. However, a closer examination reveals potential drawbacks, raising questions about its efficacy and impact on the housing market. Despite its roots in a methodology designed to support appraisers, Value...

Damned If You Do and Damned If You Don’t 34

Damned If You Do and Damned If You Don’t

Damned if you do, damned if you don’t has become the new normal in the real estate appraisal profession. The government and those that write the rules have made it illegal (a punishable violation) to refuse an appraisal assignment in an area which consists primarily of non-whites. The government and those that write the rules also state the purpose of an appraisal is to determine the value of the home/property in its market setting, so an underwriter can make a lending decision. Back in the day, this protected the lender from lending more than the home/property is worth. It also...

False Claims of Racism Against Appraiser 39

False Claims of Racism Against Appraiser

…my career, business, and health at risk due to false claims made by a homeowner.  As a professional real estate appraiser with many years of experience, I have seen my fair share of disputes between homeowners and appraisers. However, the situation I am about to share with you is one that has left me shocked and appalled. It is a story of false claims, intentional infliction of emotional distress, and the damaging effects of a homeowner’s actions on an appraiser’s career, business, and health. It all started when I appraised a veteran’s home for a potential refinance. From the very...

HUD Mulls Use of Convicted Felons to Ramp Up 'Discrimination Testing' 29

HUD’s Use of Convicted Felons to Ramp Up ‘Discrimination Testing’

It wants to bootstrap released felons by allowing them to work as so-called “fair-housing testers” for the many nonprofits HUD provides grants to… If the rule is changed, the HUD-subsidized nonprofits could hire felons to ramp up sting operations against real estate brokers, leasing agents, mortgage loan officers, escrow officers, title officers, appraisers, property managers and others.  Few would argue that society doesn’t benefit when convicted felons are rehabilitated and re-integrated. But according to a frequently cited study by the Bureau of Justice Statistics, about two-thirds of released prisoners are arrested for a new crime within 3 years, and three-quarters...

Appraisers Destroying Goliath's Messaging 35

Appraisers Destroying Goliath’s Messaging

Goliath’s strength is in his messaging. It is appraisers who are destroying the message.  The seeming destruction of the appraisal profession by the federal government, GSEs and lending stakeholders is a collective action problem. Appraisers are responding to new GSE and lending dictates with reactions based on our own personal well-being. Not enough people speak up or stand up to change the trajectory of the narrative. Or so it seems. Appraisal waivers, hybrid appraisals, automated valuation models, all based on the last 13 years of data collection by an entity I will call Goliath has created a paradoxical inversion of...

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