“Restorative appraisals for equitable community development.” Ah… If only price was the same thing as value… “The restorative comparative value would compare housing stock rather than neighborhoods.” It’s the ‘helicopter house argument. If only this same house was located in this different market in an entirely different location… So how long do you think it will take for builders to adopt a uniform land cost to buyers standard, regardless of how much they paid for said land to develop?

Check out this nonsense:
https://web.archive.org/web/20230924005144/https://challenge.economicarchitectureproject.org/featured-innovators/rosalind-williams/
AI is hosting a webinar on 8/16/2022.

Using bias to fight bias. Brilliant.

This is another consequence of the appraisal management industries propaganda and the failure of the Appraisal Foundation to counter the nonsense. The steady stream of propaganda and self serving advocacy from these institutions has people actually believing appraisers can exist with extreme discounts, that we are actually going to be willing to be the sitting duck and complete hybrids. We’re about to lose another 50,000 appraisers if companies like Radius and all the ridiculous amc’s continue to purposefully suppress appraisal service fees and duties and too few appraisers resist.

Pat,
Most of the details are freely available in article after article on the web. You can start here and follow the thread: https://www.workingre.com/first-discrimination-lawsuit-what-it-means-for-appraisers/.

Rafael, the boards and board members can be sued.

Hmmmmmm

Strange isn’t it!

They can know easily if the appraiser represents him/herself at hearing, board meeting, etc. not everything is done by mail, email, etc.

Baggins, my point exactly!

If E & O insurers were savvy THEY would be investigating the AMC that is on social media bragging about appraisals being done in 24 hours or less and even identifying the location of said “appraisal”!

Their mutual admiration society is flat out hysterical.

We don’t know the details in any of these alleged incidents. You can’t defend yourself from a loud ghost.

They are DIRECTLY responsible for not hiring the appraisers knowledgeable in the subjects market area. Whenever there is a class action suit the AMCs might be a major target.

Doesn’t everyone believe selection is strictly about fee. Every AMC knows who’s who in the areas they cover.

Not hard for the AMC to show they have no knowledge of an appraiser being racist or even know that the borrower is a minority. It would be like suing Angie’s List because the contractor was racist. I doubt they are worried.

Follow the money. Obvious targets for financial litigation come first. Should one suppose that amc’s do not advocate for lenders interests first and foremost? The whole unbiased safeguard thing with amc’s fell flat from the start. Hence commentary such as; instead of losing one lender client, if an appraiser upsets someone at an amc, lose all the lender clients at once. Amc’s, the long arm of the lender. Amc’s may very well fall into this investigation realm not by purposeful action, but rather by consistent and predictable discounted services preference. Who’s better equipped to withstand accusations of this matter based on necessary attention to detail; The appraiser whom completes 4+ a day with all sorts of ancillary services, or the appraiser whom completes two or three a week and refuses the performance reduction pressures? One feels bad for appraisers whom used typing services where such language may have been systemically present.

This is the point, the amc volume based model itself causes more risk and harm than good, they will naturally and for financial reasons, be on the front line of mass investigation events. Stack on separation from loan production rules which created the need for unnecessary third party amc companies in the first place. Nobody knew the exact details but we knew, one day…

Nice long post about AMCs that we already know about, but it doesn’t answer the question. The question was more from a logical point of why should the AMCs “be wary” when they have no say who gets a loan or what the house should appraise for.

Great post, thank you!

The appraiser mentioned in this article was accused of bias because she used comparables in the subject’s neighborhood. The second appraiser used comparables in another neighborhood. Because that appraiser came in higher it is considered correct. It sounds to me that the lady appraiser approached this assignment using sound principles, but that is not what the regulators want.

That is an interesting turn of events. FOIA is not by permission or consent, it’s a requirement for transparency. Individual bureaucrats don’t make FOIA rules or get to decide what FOIA standards apply. HUD Is not above the requirement, even if they’re rather new to dealing with a specific line of requests. Not sure if these are helpful to your cause, but the issues of slow walking requests you speak of are rather common place, and predictable. Key search terms; stalling out FOIA requests, HUD. Or similar. FOIA is a specialty to itself, so to say the least; it’s complicated. If they’re slow walking you, research the details if that’s even allowable activity. Counsel may be helpful. Is there even a limit to how many requests you can file and where? I’m not even sure where to begin with that but thank you for at least trying. I’m just kicking you out a few random links here, not sure if they’re really helpful though. With so many departments to send FOIA requests too within HUD, surely there must be more than one contact and request location option.
https://foiaproject.org/about/
https://www.justice.gov/oip/foia-update
https://www.justice.gov/oip/doj-guide-freedom-information-act-0
https://www.hud.gov/sites/dfiles/CFO/documents/2023_HUD_Congressional_JustificationsFINAL_electronic_version.pdf
(Control +F to call up the pdf term search tool.) FOIA:
“The Office of Administration intends to combine the Freedom of Information Act (FOIA) and the Privacy Divisions with the Office of Digital Enterprise. The name of the newly formed organization will be the Office of Government Information Management. Additionally, a new office named the Office of Administrative Services is proposed in 2022. This Office would include the Administrative Officer and support staff.”

For starters, the amc purposefully excludes appraisers from working opportunities with the amc’s unethical non separated billing practice which is in violation of the uspap ‘management rule’. “One shall not provide a thing of value to be the preferred selectee”, or something to that regard. Yet, the more the appraiser discounts, as cost savings from reduced service costs are not returned to borrowing consumers, the greater the financial incentive of the amc to assign that appraiser more orders ahead of other appraiser vendors.

So to the appraisers soon to be investigated or already being investigated; still think programs like alamode comp sharing, data master, third party inspectors, report typing services, hybrids and desktops are a good idea? Limiting conditions and extra ordinary assumptions won’t save you from the CFPB. If you ran that through an amc, double your liability exposure factor right off the top. Keep up with that volume, it helps keep the scrutiny away from honest detailed manually oriented task appraisers whom refuse outsourcing, refuse hybrids, and refuse amc’s. I’m not worried about biased investigations, because I guarantee all work was completed myself personally, no help, no report typing services, no third party help, no inspection help or data gathering runners, and completed to my best of ability ethically compliant report development methods. A competent reliable appraisal report completed for $50-$100 dollars in a mere hour is a pure illusion, it can’t be done.

My vote is for EO insurers to charge appraisers whom complete volume based hybrid appraisals a higher rate, and tag on an additional rider for additional cost if they’ve also bought into the amc illusion. Those qualification questions for insurability and cost should start including more narrow ranges for total number of reports completed, and additional questions about outsourced service support. That’s where the risk is at. One size fits all umbrella policies were for the old appraisal model, which is no longer the status quo. imho.

How does a appraisal board know what the color of a person is?