The fees for the new 3.6 should be 3.6 times the fee we charged for 2.6.

We Appraisers are long past overdue – we should have banded together long ago and lobbied to make AMC’s ILLEGAL. Any Lender to stupid to have an Appraisal Department is to dangerous to be in the lending business to begin with.

Desiree… the GSEs seem to be tossing a lifeline to some lenders, but notice there’s no similar lifeline for appraisers. I can’t help wondering whether they fully expect the disarray that’s coming. If the transition turns into a mess, it would be very easy to point to appraisers and the appraisal process as the problem and use that as further justification for eliminating more traditional appraisals.

Meanwhile, appraisers are being marched toward the slaughterhouse. We were blamed for 2008, we’ll probably get blamed for whatever problems 3.6 creates, and before long somebody will figure out how to blame us for the national debt and climate change too. Same old story…

Tick Tick Tick… That may be true, but I think it will be many years before AMCs, AVMs or AI are equipped to handle more complex appraisal assignments well. We all know there are things we pick up at a property that simply don’t translate into photos: the feel of the neighborhood, smells, noises, deferred maintenance, odd layouts and all the little things that affect how a buyer might react. Human analysis is still very necessary.
Will that still be true in 10 years? Maybe not. But as a semi-retired appraiser, I only need four or five assignments a month to meet my needs, and there are still enough people who want the human touch to keep me busy. Your point about county assessors’ is very valid, though. They really are much more dependent on big data and mass appraisal techniques. My concern is not for me, it’s for younger appraisers that are investing significant time and money into a profession that may not be fruitful in the long run.

Of course, in classic GSE fashion, they refuse to call it a delay. They are still insisting the November deadline is real, but lenders can now ask for an exception. The catch is simple. If a lender drags their feet past March 1, 2027, their legacy reports get hit with a 999 risk score in Collateral Underwriter & their representation & warranty relief disappears. It’s the usual mix of pressure & incentive.

The software situation is its own comedy. ACI has essentially pulled the plug on the initial rollout. Instead of updating their desktop software, they are trying to move everyone to their new web platform, ACI Sky Workbench. The word is they will not be fully operational until well into 2027. If you rely on ACI, you are stranded for now, stuck waiting or switching vendors just to keep working.

Meanwhile, the message in this article is spreading fast. Several state boards are now putting the Cert 25 issue on their agendas. Regulators & panels are starting to recognize the confidentiality problem & the size of the loophole it creates.

The truth is simple. No one is ready for this. Not the GSEs, not the software vendors, not the appraisers & not the lenders. We are heading into a messy transition where we will be juggling both formats depending on how unprepared each client is.

Brent, they physically get it from the lender, but they get the legal permission to exploit it from the appraiser’s signature.

That is the entire point. If the lender shares the report on their own, that is the lender’s business. But Certification 25 doesn’t just say the lender will share it; it requires the appraiser to sign a document agreeing that third parties have the right to store, copy, analyze, distribute & replicate that data.

Under USPAP, the appraiser has a strict duty to protect confidentiality. We cannot actively sign a blanket, pre-printed clause giving third-party data-miners our professional blessing to redistribute assignment results and interior photos indefinitely. The lender handing over the file is a physical action; the appraiser signing Cert 25 is a unilateral ethical concession. That’s the structural trap,

Stop making so much sense Brent.

What about Fannie Mae/Freddie Mac, secondary market, other lenders if/when the loan is sold

Amen

Reverse the logic.

If they’re not an intended user, why are they given the report, and all the data their in?

Cert #25 doesn’t have anything to do with intended user. It only says that the lender/client may disclose or distribute the report. In fact, it states any person or entity who receives a copy of the report does not become an intended user.

‘Pre printed conflict’.

Let’s check in on the selling guide.

https://selling-guide.fanniemae.com/sel/b4-1.2-01/appraisal-report-forms-and-exhibits#P3591

Fannie Mae will accept the following additional notice or statement when appraisers believe the lender/client is the only intended user:

“The intended user of this appraisal report is the lender/client. The intended use is to evaluate the property that is the subject of this appraisal for a mortgage finance transaction, subject to the stated scope of work, purpose of the appraisal, reporting requirements of this appraisal report form, and definition of market value. No additional intended users are identified by the appraiser.”

Uh oh…. >:(

National franchise appraisal firms whom also function as unlicensed amc’s just hopped into the pool with you. They brought their lawyers, lobbyists, advocates, salesmen, a squad of fast tracked newly minted appraiser licensees with them. Is that your private client they are talking to right now?

The time to reign in this model was the last decade. Tomorrow is already too late.

The most interesting point that I see is the inherent pre-printed conflict. The addition of the appraiser agreement for any reader to distribute is clearly our agreement that those folks can rely on that information, and yet the last sentence of proposed #35 states that the appraiser(s) shall have “no liability” for any such uses. It seems to me that such contradictions are a lawyer’s dream. Why in the world would we allow and authorize something we are not liable for? Sounds a little like a quitclaim deed to me, and God help us if the report is deemed ours in litigation. I’m personally rather skeptical of suggesting that it’s OK with me for you to dissect and disseminate my data and that I am, at the same time, not accepting liability for it. Any lawyers out there with a sensible interpretation?

What a day. Image.

The argument is this creates an illegal work around of due process.

I’m not giving any certifications too much credit. The three year previous appraisal service provided disclosure rule, turned into a certification the appraiser has not provided service within the past three years of the property. Thereby prohibiting repeated valuation service for a three year period. Never what that disclosure rule was meant to accomplish.

As stated in certification guidelines somewhere, they are non negotiable and appraisers can not write them away or supersede any of them with written language elsewhere in the report.

Contrast this to the previous certification regarding intended users. Image attached.

‘May rely on’ Vs the long list of new allowances.

How in the heck can appraisers control any of this? Why would such language be present in the first place? The certification disclosures are there to validate and define the scope of work and duty requirements of the appraiser, not other parties. The previous certification was an acknowledgement to the necessity of report processing for the specific purpose of mortgage lending. It was not an open ended invitation for anyone to treat the report as an owned object or work they could freely disseminate or recreate, with the appraisers associated permission to do so.

The GSE’s have grown entirely too comfortable with dumping everything on the appraisers. It might be slightly challenging to bark mandates in an empty room.

I can see AMC’s taking over all types of private work including assessing functions This could result in property owners being reluctant to appeal their assessed values because the assessor is backed by an AMC and a massive (so called) data bank. And this may lower assessing costs for municipalities by doing away with much of the assessing staff and associated expenses

Time will tell. Don’t be surprised when private work takes an unexpected turn, hopefully not in the middle of litigation.

I won’t go into detail because I don’t want to provide ideas for AMCs

All types of Commercial appraising is also on notice.

I’m entertained! Absolutely!

I think Midwest brought up the point about ‘understanding banking’. Please, allow me to help. Deposit guarantees… One may ponder the reason for the appraisal licensing program in the first place. Applied checks and balances systems to inhibit the known ongoing practices of predatory lending and out of control spending.

The rich irony of the same companies being regulated and restricted, having co opted their regulators, whom then were instructed to write away the regulatory protections which restricted their own predatory behaviors. The people in the industries being dismantled, like appraisers, have developed a sort of stockholm syndrome. Over time with so many incremental reductions of their participatory contributions, having been steadily rewarded for ongoing capitulation over many years, many appraisers really did not notice or care when the death blow finally hit the industry. Rather many actually stand up for the process, defending the lenders and other special interests whom direct the appraisers own business dismantlement and participatory reduction level.

Failure to prioritize consumer protection principals, to not understand the need for regulatory restrictions in the first place, is among the primary reasons why the appraisal industry will continue to experience prolonged retraction and attrition. It is why the appraisal trade groups have become effectively obsolete, having been co opted themselves as well, they answer primarily to stake holder interests rather than the merits of why appraisal licensing exists in the first place. Appraisers have never been and were never in place to defend lenders interests under the GSE system structure. The appraisers participation was required, to fulfill basic checks and balances structural modeling, for financial safeguarding reasons. The principals behind ‘appraisal independence.’ The more modern regulations written as a response to the harm American consumers experienced when financial systems ran amok. Smart and financially responsible lenders would voluntarily use appraisers in their appropriate capacity to provide financial safeguards to their own lending activities. Irresponsible reckless lenders whom dump the risk and losses back to the taxpayer tend to see less value in having appraisers around, have subsequently written out the appraisers formerly routine and robust presence in the lending industry. Banking…

‘It is my opinion that you do not really understand the concept of banking.’

‘A triumph of hope over experience’.

(trying to get both video play boxes to appear at once.)

We’re all pretty much in agreement that the GSE’s want to eliminate independent resistance to increased loan production. Debt traps for everyone!

Their day will come. Public sentiment has shifted. Sweeping all the foreclosures away behind the scenes with the Whole Loan Sales program, does not mean the people subjected to these debt traps are not talking about what happened to them.