I also work for VA and no one else !!! Glad to hear it you are on their panel !!!

True (last sentence)

I used Restricted appraisal as an attempt to protect my self and recognize that all F.M.V.s are not the same.

For instance one lender might propose a 95% loan against a 2nd and only 5% cash down, with a high interest rate. Another might quote a lower interest rate, but with 20% cash down, and yet another might quote lower interest rates with the borrower submitting additional properties.

Not all borrowers nor lenders are alike. Not all values are alike, even for the same property.

The 1004 form includes a description of the terms under which the loan is being made, many times the agents, lenders or mortgage people ignore this.

I volunteer that my appraisal standard is ??% nor more than 1.5 pts against an 80% 30 year mortgage.

From time to time I find evidence that the higher values are supported by the looser terms, and I may discuss those items within the report.

We appraisers seldom know the terms which closed the sale, we do note from differing prices from our knowledge? Most selling-buying agents will tell is asked why basic offers changed in escrow.

Good appraisal practice takes lots of effort and time which we should charge and be recognized for.

Traditional state definitions considered the party that paid for a service to be the client regarding that service. We used to advise borrowers “Though you are my client, you are paying for me to provide my impartial and unbiased professional services to the designated lender you have chosen to do business with. Implicit in our relationship is the requirement, knowledge, and expectation that I will provide my services in accordance with USPAP; FNMA Guidelines and any specifically known requirement of the lender related to the value being appraised.” Sometimes those specific requirements directed me not to discuss the value with the client & I’d have to direct them to tell the lender to let me know it was ok, when a question arose.

It was a much more honest & open way of treating the consumer/borrower

Because TAF forgot, or chooses to ignore their PRIMARY self described task of protecting the public trust in deference to the dictates of their sponsors (THEIR clients, if you will), we as appraisers have allowed a dishonest definition of who or what a client is to be subverted. In days of old, the lender was never anything more than the intended user along with FNMA.

ABA is merely propagating that erroneous definition and taking it to a new level. A level that ignores many states mandated fiduciary obligations to the people that pay for the appraisals…regardless of what they are now called. A single party in loan transactions is now arbitrarily redefining legal terms without input or opportunity for input from the other parties to a loan transaction and appraisal.

THAT is the message consumers should be upset about. THAT is the message and practice they need to be educated on. Educating them to the fundamentals will assure we all have enough work.

Phil referenced a letter from Sharon Whitaker VP of the ABA speaking about the increased threshold, Raising the Deminimus. The appraisal ordered for the bank is for the bank and not the consumer. Consumers “Should order their own appraisal”. Opens a new market for appraisers. Very important information Ms Whitaker’s letter https://www.aba.com/Advocacy/commentletters/Documents/Appraisal-Threshold-020519.pdf

No Chris, to my knowledge Guaranteed Rate handles all of their appraisal orders in-house, and thus I receive my work directly from them with no AMC involvement. Last month, my fees ranged from $450 to $600 for what I would consider run of the mill assignments. Big picture, much of my work is by way of the VA which pays $600.

Seek the truth.

Loidene – Clear Caps “clients’ have forgotten what hiring a professional means. Imagine going to your doctor and telling HIM (or HER) that you are charging a $13.00 fluid replenishment charge every time he draws blood; plus a reading or listening consultation charge whenever he explains his findings to you.

ANY appraiser that puts up with this garbage has an exceptionally low opinion of themselves. It reeks of the late 19th century and early 20th century ‘company store’ approach used by mine owners against their employees.

Bill Johnson, ..certain client changes do not warrant civil responses. This is not a client that is worth working for anymore. In fact, they have dropped themselves down to being a client with policies that IF followed by appraisers put them at much greater risk of making an error. Even great appraisers, like I believe you to be from past posts.

I think my response would be to point out that their shortened turn around time of only three days does not (always) allow adequate time for necessary research or cold review of completed work. Typically five to seven days is necessary for this. Further, that as a great appraiser, you are NOT slow enough to have to accept downward price pressure to below reasonable fees for the area. They need to comply with Dodd Frank’s reasonable and customary fee requirement.

Instead of encouraging appraisers to cut corners by unlawfully coerced lowered fees, they should be encouraging appraisers to take MORE time to complete work so that errors are reduced and report quality is maximized. I’d remind them of ALL the things THEY are required to do to assure their LENDER clients are in compliance with federal regulations and ask how their new policies achieve this?

I’d do it in writing and be sure to send a cc to The Appraisal Subcommittee; the FFIEC and to Congress Member Maxine Waters as Chairman of the House Committee on Housing and Finance.

Spend the time saved by looking for a new client that is more honorable.

Bill….are you saying you do appraisals for $275.00 ???

That client would be Guaranteed Rate Loidene. A good company, but the spin I was told is that it should cut down on appraiser conditions, and thus save us time. The problem with that logic however, is that I’ve done 10 assignments for them over the past 30 days, and I’ve had NO conditions. Those same 10 assignments this month, will set me back $130 at $13, or $230 counting the original $9.99. All of this with their due dates being moved up to 3 to 4 days (my turn time from assignment 24 to 48 hours), instead of their company policy of 7. They said because its slow, we should be able to work faster. Welcome to the life of a CA big city appraiser.

Seek the truth.

The VA loan is a recourse loan, when the veteran defaults and the equity is lower than the value of the loan balance the veteran is liable for the deficit.

How would the courts the state, federal politicians, and the laws work.

Clear Capital and the Corporate world wood loose and it would not be a contest.

Appraisers are not the only solution for the the real estate loan industry, appraisers are no more honest than other pro’s.  Legislating, issuing rules and licensing have not been effective, and they’ve been tried over and over again.

Appraisals are an excuse most effectively used in prosecution.  Fees are higher for appraisers in judicial hearings

P O O P!!! I thought I was being charismatic. Oh, unless ya meant the other part.

Roy excellent points and all true. I got in about 7 years after you did. The days of three handwritten ‘comps’ with no more than an address and qualitative comments with a number on the bottom as letter appraisals had almost completely ended by then (circa 1986).

I saw a distinct upgrade in quality after USPAP was finally implemented around 1991 – two years after being passed. Appraisers all across the country seemed to be trying to comply under the silly notion that government was serious about cleaning up the profession.

By 2000-2002 it seemed the pressure was on again to look the other way or only reconcile to high ends orf ranges again. USPAP had become a moving target so no one bothered to ‘near-memorize’ it anymore. We KNOW by 2007 that low end AMC pressure had pretty much wiped out quality and being allowed adequate time for completion.

Lets not forget when FDIC did forensic reviews on over half million Countrywide and WAMU appraisals they found 90% were deficient (non compliant); 95% were over valued, and 97% were egregiously deficient (whatever that means).

HVCC was a knee jerk reaction that only showed more legislators how to get into the feeding trough line AMCs were putting out.

We are out of the Great Recession now in nearly all categories in most areas, but that does not mean 100% of old values have recovered. My own property was $650k in 2006; bought by us for $325k as an REO and if I believe my own ability to objectively analyze value it should be superficially somewhere around $450k+- today. Zillow would say over $500k to $550k. Point being is that we have not recovered all lost value; though Id still argue we are close to what real value should be (in my area) without insanity being the main motivator.

No appraisal or a PIW? I could easily make a stacked deck case for $500k and accept a ‘cut value’ down to $450k. OR an 80% LTV cash out refi and walk away with $80k. No need to worry about ANY of those non apparent issues that I also know COULD cost me or subsequent buyers another $50k to cure/fix, right?

Roy the sad part is that there are so many low fee form fillers out there that even with an appraisal my property would probably slip through cracks it should not. If morality and integrity were not factors, I could pretty well guarantee it.

So, overall our professional quality has diminished I think. TAF and states have done NOTHING to improve it. Nothing. Federal legislators have done nothing meaningful to improve appraisal conditions or simply “Public Trust” in the appraisal process. They left their Congressionally mandated American Real Estate Appraisal path and got lost somewhere in the Enchanted IVS Forest.

Roy one exception; the American Guild of Appraisers is and has been unrelenting in its efforts to protect and educate appraisers, and to fight for necessary appraisal reforms. We are mainly volunteers. We could certainly use the help of more folks like yourself. Join us. contact janbellas@appraisersguild.org

Whether you join AGA or not, keep writing and sharing your views. (but join anyway!)

SCUM.