Appraisals in ENV format
From my perspective there seems to be an increase in the number of appraisal requests that require the ENV format. The conversion to ENV of your completed appraisal report is usually not an exact copy of the report which the appraiser completed and signed. Some forms may not convert, other may separate your photos from the text which go along with the photo and the order of the forms in your report may not be the same and there may be other changes to your report. This should be a concern to every appraiser since the client/lender, is not getting an exact copy of your appraisal. This means that the appraisal report you completed and signed is NOT a copy of what the client receives. Most appraisers have a statement in their reports that states something like the following.
The attachments may assist the user in understanding the relevant characteristics of the subject property and may provide additional information not covered in the URAR which is relevant to the analysis of the subject property. Failure of the user to read the complete appraisal report in its entirety may lead to conclusions not intended or supported by the complete appraisal report. This appraiser does not accept any responsibility for actions of users based on selected portions or condensed versions of this appraisal report.
I do not believe that this statement is sufficient when the appraiser has accepted an assignment that he/she knows in advance that the report the client will be receiving will not be an accurate copy of the appraisal report which the appraiser has completed and signed. Personally I do not accept assignments that require that the report be submitted in ENV format. I realize that all appraisers do not have the luxury of declining these requests, however if you do accept these assignments you should attempt to protect yourself as much as possible. The appraisal software companies have made it easy to convert your appraisal report to the ENV format to comply with the client requests, that is not the problem as I see it. The problem as is that you the appraiser are knowingly providing your client with a report that is not a copy of the report that you completed and signed. I would think that this would be a violation of USPAP however that is for someone else to decide.
After some discussions with my son who is also a Certificated Residential Appraiser about the potential problems when converting your appraisal reports into the ENV format to submit to the AMC/Lender we have come up with a statement that should probably be included in your appraisal if it is going to be converted to ENV format. I suggest that the following statement (or some variation of it) be put in a prominent place on a form that you know will be converted correctly.
This report was delivered to the Lender in ENV Format as requested by the client. The conversion from the Original Report into the ENV Format DOES NOT always include every page or all of the information contained in the Original Report. As a result of this conversion process any resulting report(s) created from the ENV Format may NOT contain all the data or pages needed for the reader to understand and follow the flow of the appraisal report.
The appraiser has NO control over the final results of the ENV format file and takes no responsibility for data that may be missing in reports in the ENV format or files created from that format. It is recommended that the Lender obtain a Complete Copy in PDF format and if needed also in the XML Format from the Appraiser. This can be obtained with a simple request to the appraiser.
Stay safe out there and Happy 4th of July!
- Changes from Fannie Mae - February 3, 2022
- AMC Reviews of Appraisals - November 27, 2019
- New CA Law Negative Effect for Appraisers - November 8, 2019
I include a disclaimer in my report about how horrid the ENV format is. I also have started embedding graphical images of my general text addendum. I use a lot of tables and charts to reason about a market and ENV supports only plaintext formatting.
I had to also leave behind a keyword searchable version of the GTA as reviewers don’t actually read your report. So, to avoid people asking me to comment on 20 things I already did, I learned to leave both versions inside the report.
ENV is something the late 90’s threw up and for some reason has not been cleaned up. Probably legacy platform issues.
The day ENV dies for good will be a joyous day…
I like the idea of graphics to support critical report elements, but you may want to check one of MISMOS already stated goals. The complete elimination of charts and grafts. Even from commercial property narrative reports.
Until appraisers from ALL peer and legitimate appraiser advocacy groups & organizations take back our profession and dictate the standards that are required for a credible appraisal report the never ending battle by mortgage bankers to eliminate all impediments to closing deals will continue.
TAF is not that independent source anymore (if they ever were) . Not as long as they take their marching orders from the non appraisers interests
Mike,
What a stupid and horrible goal. Has MISMO forgotten that real estate properties are unique and that detailed arguments are often needed?
I am working towards eventually exiting lender work. May take some time, but there is little future in lender work appraising. The lending world wants widgets and are trying to commoditize our work. I am going to try and build up a book of business outside that sphere.
I have not had a request for an .env file for over 5 years. Clickforms used to make you pay an extra fee in order to convert the file. That lasted about a year and I stopped accepting requests from lenders that wanted an .env file. My problem…..was solved.
CoreLogic now owns FNC. CoreLogic own ACI, alamode, Mercury and Appraisal Scope. It would stand to reason they will require the .env format on all those platforms. This should be reason enough not to accept any request for .env files. If it is going to go away, appraiser must be the ones to refuse to deliver in .emv format.
I won’t do ENV, it’s a garbage format. Since I deleted Clear Capital I haven’t had any requests for it.
I have been saying this for years! And why did the Appraisal Institute back this? And from an enforcement standpoint, if you know that this file format changes things, you better have a copy of the ENV file in your work file or you do not have a TRUE copy of the report.
I refuse requests for ENV files. Not only for this reason, but Corelamode robs customers of an extra $300 + for the conversion software annually. That’s such BS.
John, you raise (or more accurately REMIND) us all that WE are responsible for assuring that our reports are not misleading.
As you point out, the language likely would not protect us in an FDIC / Department of Justice or State Regulatory complaint because FNMAs boilerplate verbiage tells us up front that all kinds of unidentified third parties may claim a right of reliance. I too have effectively stopped doing appraisals for loan transactions (with only rare exceptions now).
We have had ZERO control in how our appraisal reports are presented to third party users since we stopped delivering in locked-pdf formats; and switched to formats that make it possible for Corelamode and FNMA to steal our data through data-mining.
IF this was ALL that was taking place, I’d say its nothing more than an appraiser business decision. But this is NOT ‘all’ that is happening. Our already summarized reports are being further reduced to as little as single line entries in bulk securities purchase agreements.
Major investors such as pension funds, international banking interests; and (potentially) sovereign investors’ own advisers are relying on these minimally stated data summaries to make hundreds of million dollar investment decisions.
When the loans go bad and they have gleaned whatever recovery they can from insurance (FDIC, PMI, MMI etc) they’ll simply sell the heavily discounted defaulted obligations. The people THEY sell to are the ones that will start coming after appraisers automatically in pursuit of E&O claims. Doubt me? It ALREADY HAPPENED last time around!
There is NO AMOUNT of limiting comments we can add to our appraisals that will prevent us (at BEST) from having to spend tens of thousands of dollars to defend ourselves against these kinds of claims…or at least none that clients would accept because it would diminish the ability to commit the very frauds they are perpetrating on their customers.
Please don’t lose sight of the fact that every single hybrid, evaluation, have-assed-scope-limited appraisal leaves the burden for proper compliance with USPAP squarely on the appraisers shoulders.
Declare your independence from ENV formats today. If the users of our reports want to facilitate tampering with them, let THEM come up with software that does so AFTER we have completely finished with our secure delivery reports.
Mike I don’t know what the ENV format is. However i do understand loan discounts, the freedom for a business man to contract for legitimate products. I agree that defaulted obligations can be REAL source of litigation and appraisal business, and an opportunity for the resourceful Real Estate appraiser-Broker.
I have found that Microsoft word can format a wonderful defense and argument for most of the basic economics required. The changing format offered by someone else’s form can be ruinous.
Insurance can only defend us, they can also decide that a payoff is cheaper than the cost to our reputation.
Create a standard map page. Change the pre entered language into something more meaningful, ‘location map’ now becomes ‘Subject only close view’, submit via env; Stip! ‘Appraiser to include the requested map’. You can not get the report past auto review unless you change the map label back to the generic coding. There goes the quality score grading which future work depends on, and they wonder why they’re having a hard time attracting new appraiser talent. Apparently the env software coders never actually used a live version of appraisal software and were not aware one could customize the form labels, env recognizes the map page by the label, not the substance of the page itself. There is a very long list of technical deficiencies with env conversion software.
That’s what passes for ‘advanced software’ these days. This industry is now run by tech nerds whom have successfully implemented a series of illusionary value in use product schemes, with the goal of eventually replacing us with themselves. It’s the gotcha game, the more overly critical their software review protocols are, the more stips and time wasting events the appraiser deals with. Separation from loan production rules and the mismo like technological approaches represent a massive waste of human energy and time. What happened to sending a private report by email?
There has been zero new meaningful jobs created in the appraisal industry in over a decade. There has been a massive bureaucratic build up of non accountable persons, disposable telecom workers, non qualified technologically focused people, and salesmen. These people are incredibly hard to work with because they do not share similar focus, goals, operational compliance with ethical principals, and the list goes on. We would all be better off working directly with other licensed accountable professionals, people like lawyers, realty agents, licensed mortgage brokers. Only actively licensed appraisers are qualified to manage appraisal panels, the rest should be fired immediately. .ENV, unacceptable assignment conditions.
Standard service terms quote language; Will submit XML, PDF, but not .ENV.
The Env format also includes a PDF of your report, Just like an XML. I’m not saying both can’t be messed with, but there is an additional element of security, even if not perfect. These days, no security is perfect.
If someone’s report can be routinely meddled with by design, then we aren’t talking about ‘perfection’, we are talking about deliberate circumvention of the ability of appraisers to reasonably control how their reports and conclusions are considered. I write mine with the intent that the who thing is necessary in order to convey my thoughts and conclusions. IF an intended user chooses not to read it that is on them. If an intermediary intercedes between me and a far downstream investor, to provide abbreviated or truncated data then that’s another issue completely. It amounts to an unauthorized use of unauthorized tampering.
Any report can be falsified, we can only defend our work before our accusers. I retain the right to collect any costs incurred in the engagement letter included in all reports.
Or at least I did when I had a license
Based on what I see in the files the ENV does not include a PDF. At least not for 1004 reports. I see XML files, JPEGs (including the appraiser’s signature), but no PDFs. The PDF that is typically embedded in the MISMO 2.6GSE XML is not included as well. I know this is a dead thread, but I’m just adding information for future reference.
Once I heard from another credible single-family appraiser about how they can change the .env formatted reports, I asked one AMC I had just signed up with and she admitted they change the order of the report from what we submitted. I have never provided a .env report assignment from anyone and will never consider it. In fact, I’d rather not do any work for lenders as long as they use AMCs period.
We must have our standards and stick to them. If appraisers had gone on strike and refused all work before it got even more abusive a process, we would have been in better condition as a profession, but some people had to underbid and do shoddy work for low life AMCs to put food on the table. I suggest they get jobs babysitting children which would be more remunerative and rewarding than using your education, training, expenses and efforts in time and energy, compared to appraising for loans that wind up at fannie or freddie.
Please, appraisers stop being stupid and cooperating with the dumbing down of our work by banksters and lobbyists working for right wing guys who robbed us of our honorable profession while we were trying to tread water until they realized they needed us to do our job as we see fit because we can be held responsible for errors regardless of having E & O. Wake up people, our profession has been taken over!
I’ve never submitted a .env report either; though the AMC I’ve done a few assignments for may upload them that way. (I email them as completed pdfs and on rare occasions as whatever file ext Bradford saved them as and before that the .zap files for alamode).
There is no reason for an appraiser to have to upload anything other than a pdf. Our reports are not prepared with the intent that they be decompiled so ‘clients only receive what they want’.
The last time I used ENV it changed my appraisal substantially. (Hence the last time) It was a manufactured home appraisal. The firm required me to check manufactured. I did. ENV unchecked it. I tried 5 times to send it checked. I refused to upload it under the ENV because it kept unchecking the box. The AMC finally accepted the pdf after I proved what the program was doing. I never accepted another order for ENV.