How to Destroy the Appraisal Profession
Anytime the government gets involved in an issue, it tends to have more adverse effects than positive ones. It makes things worse when they only have their plan in mind and NOT the FACTS from the people they are about to hurt. This is especially true in the Real Estate Appraisal profession and the newly introduced H.R. Bill entitled: Fair Appraisal and Inequity Reform Act of 2022.
It’s essential to bring some information that not one person in the government or the people they are getting information from is talking about.
First let’s step into my time machine and go back to before the housing crisis and then soon after. Let’s start with pre-2007-2008.
Before the financial crisis in 2008, many appraisers had offices that employed multiple appraisers and trainees. The numbers don’t lie on how credentials went down, as seen below:
- 2007= 121,407
- 2008= 120,551
- 2009= 116,791
- 2010= 110,026
- 2011= 106,103
We had the highest number of credentials issued between 2007 and 2008 (121,407 and 120,551 certifications, respectively).
In 2009, the number of credentials went down directly due to government restrictions on the appraiser’s ability to practice, as well as the implementation of the now-defunct Home Valuation Code of Conduct (HVCC) that then Attorney General of NY Andrew Cuomo decided to put into place due to his bad housing deals to protect his banking friends.
Also in 2008, the Housing and Economic Recovery Act (HERA) was created. Before HERA passed, there were 30,286 licensed appraisers. Today, there are only 7,321 licensed appraisers because most lenders moved away from hiring Licensed Appraisers after HERA was passed. This is a significant issue that, once again, the people looking to make the changes have FAILED to mention. I discussed this in my prior blog.
Now let’s go into post 2007-2008. HVCC and now Dodd-Frank were nothing more than laws to protect the wealthy, and today, they make others, like appraisal management companies (AMCs), rich while ignoring the FACTS. It took an excellent profession and turned it into one that many lost respect for. More and more appraisers decided to leave for better pastures, which is what happened. More and more appraisers saw the writing on the wall. Appraisers saw the businesses they built through hard work, determination, sweat and tears, go away before their eyes on May 1st, 2009, the day HVCC was adopted. The Government told every hard-working appraiser that they did not matter. As time went on, more appraisers decided to retire, find better work, or just decided to NOT work for AMCs (myself included). See, there are many things about AMCs that most don’t know about such as how they up charge consumers while looking for the cheapest and fastest appraisers to do the job, so they can profit more.
Let’s now look into and discuss the proposed bill. But before I do that, I need to preface by saying that this article is in no way, shape, or form discrediting anyone that has felt they were a victim of bias or racism. I’m just trying to put the FACTS out that the Appraisal Subcommittee (ASC), government, the Pave Task Force, and others have failed the residential real estate appraiser and the public.
I have already written about and touched on the issues of trainees, AMCs, appraiser shortage, and more in the article titled “Dear ASC: Details… Why They Matter“. So here, I will discuss further issues that many may not know about. My position within my group and the President of the American Guild of Appraisers (AGA) allows me to access more information than most.
This new bill wants to create a new federal entity to oversee the appraisal profession, which we already have.. This bill states:
To establish an independent agency known as the Federal Valuation Agency and real estate valuation standards and appraiser criteria, including promoting a fair, unbiased, transparent, repeatable valuation process and other purposes.
So the government has decided that appraisers need more oversight and to be investigated based on discrimination claims when the consumer doesn’t agree with the appraised value.
Now since many here do not pay attention to the daily issues of the appraisal profession, I’ll spell it out very simply as it’s not that hard to figure out. The ASC is that ENTITY looking to become the Federal Agency. This is my speculation, but based on the years of issues between the ASC and the Appraisal Foundation (TAF) and others, it only makes sense. So the ASC did not tell the whole truth in front of senators to make them look better and because they want to gain more control. How can appraisers support an organization that can’t even tell the actual truths, give facts and give honest statements to senators? See my last article. Now I also suspect that other larger groups (no names will be said) are also involved with this new takeover, since they have had this same idea for years now. These groups only care about money, power, and being able to assert their authority over all of us hard-working appraisers. Let’s not forget how the ASC receives cash from all the AMCs that they are supposedly regulating! Or how the ASC gets a fee from every appraiser on their roster, yet no one has any idea where that money goes to or what it is used for. Where is the transparency?
But here is the ultimate question. Where are the actual Independent Appraisers in all of this? Why haven’t we been included in the talks. Why haven’t we been interviewed by the media? I am not talking about the Appraisal Institute or the American Society of Appraisers. I say that because I don’t belong to either as many other appraisers do not belong either. It’s our choice because many of their members own AMCS, have separate agendas, and have a conflict of interest with independent residential appraisers. Both of these groups do not represent all appraisers. However, the Government has bought into all the AMCs, lenders, and other groups’ narratives but hasn’t even attempted to include actual independent appraisers in the talks. Most likely because those appraisers would tear apart this false narrative, and well, that’s not what the government wants. Elected officials are not doing the right thing for the people they swore an oath to, to protect and gather information they need to make a decision. Appraisers use the data that everyone else (Realtors, assessors, builders, etc.) use in order to develop an opinion of value based on FACTS they research to protect the public trust, a public trust the government is looking to destroy using insufficient information.
Information. This is the keyword that everyone pushing this false narrative is overlooking. So here is some factual information:
- HUD investigations: we live in a country that states, “Innocent before proven guilty,” yet HUD has been researching appraisers for racism and bias. The FIRST thing presented is a settlement amount. For example, a NJ appraiser was asked to pay $100,000 before an investigation was done for alleged discrimination. When the appraiser refused to settle, HUD asserted their authority and asked for 1) one year’s worth of files along with a list of the following: RACE or Ethnicity of a person at the house; 2) lender’s name; 3) AMC’s name; 4) value of the report. Now I have been in a major lawsuit and know how this works. However, HUD asking for money before an investigation is done is absurd. Pay it, your guilty; don’t pay it, you’re guilty, and we will make your life hard. Is this the system the government is looking to implement going forward?
- AMCs: Why would anyone take the appraisal management companies’ information as a factual? They aren’t regulated as much as appraisers. They were given the Charlie and the Chocolate Factory golden ticket. They pretty much make their own rules even though the rules said they were to MANAGE, and not dictate the appraisal process. Example: AMC contracts with a lender. The lender is later not happy with the appraisers they chose. The appraiser is removed from the panel so that the AMC can keep said client to make money. Isn’t this pressure, the very thing the HVCC and DODD Frank wanted to eliminate?
- Creating an all-in-one federal oversight organization (ASC or others): Let’s be transparent here since we know where this is going. While I can see some good in this, I see more issues going forward. All complaints go to a federal entity (ASC or others), and we take away the responsibilities of the state? Who is deciding the fate of the appraiser? Will this federal entity employ 50 state representatives on their board that knows the entire state? Will this federal entity be able to remain impartial? Will they consult actual real estate appraisers or peers?
- Lastly Transparency: Where is the transparency in AMC fees vs. fees paid to the appraiser? Where is the appraisal management companies’ transparency to bid the order out and let the consumer know or lender know? Where is the transparency in the process? Where is the transparency in how this bill will help rather than harm? Where is the transparency in the appraisal reports HUD has been investigating so that peers and others can offer information? Where is transparency in the facts?
Senator Toomey said it best, and I may misquote but I’ll try to be as accurate as possible. “There are two studies, and the info is proprietary and hasn’t been released to the public. So if no information has been released, how can we rely on it if no one else has seen it?” EXACTLY!! Why is HUD holding out on these reports? 1) They aren’t an intended user; 2) They are keeping things secret, yet they still haven’t found any appraiser guilty.
I didn’t get into the bias or racism aspect of all of this for one reason alone. Nothing HUD or the government has stated or supplied has actually shown proof. That’s not to say it isn’t there. However, how can I comment on racism when I have not seen any appraisals, when I don’t know who the lenders, the AMCs, and the appraisers are, and I haven’t read the communication between them and the appraisers. Then again, that falls under transparency which the government is not interested in.
The Government is about to destroy a profession based on opinions, money, and what benefits them, instead of protecting the people they represent. Not one appraiser was represented in front of the senators and not one appraiser was able to tell their story.
This bill if passed will force more appraisers out of the profession as more will be leaving or simply retire. The ASC and others are creating a narrative for their own gain. It’s time the government speaks to actual appraisers before it’s too late in the game.
- Look in the Mirror - February 27, 2023
- AMCs Take a Sizable Cut of the Appraisal Fee - October 5, 2022
- Proposed Rule to Eliminate C&R Fee Tabled - July 21, 2022
How about a totally independent board of highly qualified, highly experienced appraisers to have oversight power over HUD (and others with power and authority over appraisers); where HUD would have to compensate inappropriately accused appraisers for time, emotional distress. intimidation tactics, legal costs and etc. And those HUD employees responsible for being incompetent and abusing their power would be relieved of their duties. Maybe (probably not) they would think twice before savage attacks against the hard working powerless little guy appraisers who need protection against the power hungry beast. These government institutions need to have real accountability to the citizens (unfortunately this will never happen).
If an appraiser is accused of something by the deep pocket powers – instead of succumbing to the shakedown and subsequent pre-investigation /litigation $100,000+- settlement, the accused appraiser would contact the appraiser comprised HUD (or other) oversight board so they can get involved from the start.
This appraiser board could also investigate the competency of HUD employees to see if they even have the capacity to accuse anyone of anything. Also, to see if HUD is comprised of too much of a lopsided bias – instead of diversity that is well grounded in real world appraisal experience.
Accusations from powerful sources have already damaged appraisers heavily. Class Action lawsuits from appraisers are more than justified against many including much of the press. But this will never occur due the absence of funding and organization.
Unlike the meltdown of 2009, 2022 is all about dumping crap on fannie; and fannie is receiving it with open arms particularly with desktop appraisals.
Is it because they are aware our taxpayer dollars will bail them out again, again and again?!
Just want to inject something. Regarding racism? Most orders I receive are an address. At times, they are 2 names on a contract. I cannot tell whether they are black, white, or purple. I go to the address and simply do my job. It’s so discouraging to think that because of the racism card, I can lose everything over my opinion of value, and there’s a good chance I never even met the people.
The process is working. The goal since the late 90s has been to eliminate the “bottle neck” (you). Check out the time line. It comes down to this – Banks are huge and wealthy and have a VERY strong Lobby group. Appraisers are small and disconnected from each other (NO lobby or support group for the profession as a whole). It’s amazing we have lasted this long. Do the lenders really care what something is worth if they have GSEs (you own them remember) taking all of the risk? Faster is what they are looking for. Much faster – like 10 minutes from order.
Not even close!! Most small lenders can not process a loan in less than 90-120 days; and they can not role closing costs into mortgage. As long as mortgages are liquid, that market, not the lenders will require collateral verification from a neutral party! That is you boys and girls – you are giving your product away!
In April 2022, the average time to close a mortgage was 48 days according to ICE Mortgage Technology. But many borrowers will close faster. The exact time to close depends on your loan type and how complicated your loan approval is, among other factors.
“Closing times vary, as national averages bring in loans that generally take longer to close than conventional loans, like VA and HFA loans” adds Jon Meyer, The Mortgage Reports loan expert and licensed MLO. “Most borrowers can expect to close a mortgage in 20 to 30 days.”
*Credit The Mortgage Reports
You said it all, I used to enjoy our profession but not anymore and I appraised through all the ups and downs and am tired of all the BS going on now.
The creation an all-in-one federal oversight organization will be the balloon going up, for those appraisers paying attention. If you get your appraisal ran to your ‘state board’ for whatever, by anyone, will it become a Federal crime?
Will the states have any balls at all to push back, or will there be kickbacks and threats of withholding Federal funding if states refuse to comply?
An all-powerful ASC or it’s like will be the end.
I keep saying it, but this is the LAST nail in the coffin.
Yeah, like the 7 person state appraisal regulatory board can turn anything in 48 hours. Give me a break. They can’t handle existing complaint loads and commonly have a 6 month or longer out time until they even call the play as a dismissal or further investigation into misconduct. Read the FAIR act proposal in it’s entirety. How could they fit so many absurd proposals into such a small document? People wanted ASC out. They’re getting the Federal Valuation Agency instead. Be careful what you wish for.
My state board did not give me credit for some of my CE. I had 3 days to take an on-line class and send them the certificate. It has now been 4 months and they have not gotten back to me. The funning thing is the CE was already approved by the State Real Estate Commission, but the appraiser board would not except it. One class was on title work, they said that title work was not appraisal related. Should I assume that if my client gives me the title work that shows that a rural property with acreage has a recorded access easement, that I do not need to read the title nor mention the easement in the appraisal? Because according to my appraisal board title work is not appraisal related. Will that reasoning hold up if I am in court? It is a good thing that I keep all of my correspondence just in case I need to refresh someone memory later.
CJK you got tripped up on a technicality. Although classes are approved, they are not approved generally for all regulated professions. I agree with you that class is likely relevant, enriching, and should count. Due to the technicality which seems certain here; that class was not approved for appraisers specifically. If you were to argue this point, you would specifically review the material on the course approval programs and your state class lists. Link provided below. That’s why I just go through the mainstream avenues; jones, mckissock, oncourse, someone recommended calypso which I have not tried yet, etc. Consider anything not offered by the big box CE providers to be possibly off the specific list.
My state publishes a specific list which if I’m against the wall I also check to make sure the course is actively listed because it may be a possibility the CE providers approval to offer the course time period may have expired. This is the game with CE, the CE providers, and the state regulatory agency, a continual circle of approval, expiration, and course re approval, with the course often having a slightly different name variance. If you’ve ever ran through a CE class which you know you’ve taken before, but had a spelling name variant, that’s why.
https://datastudio.google.com/reporting/183942e6-5b21-44f1-b094-d48ae02162d1/page/ob5OB
Actually that is really interesting content to review, as appraisers could seek out new CE providers and new frontiers of practice. You know, those are also primary functions of appraisal boards, their function is not limited to just dishing out penalties and fines all day, investigations and such. Of the state board, there are working position assignments, one does complaints and investigations, the other does paperwork and billing, the other does renewal and ce auditing, another maintains and curates the currently approved CE list. Swear, these government people don’t know how the valuation industry works, and they’re clueless to the capability of regulatory agencies. Creating a new Federal Valuation Agency is just going to make an even greater mess of things and drive costs for valuation services up tremendously. When I refinanced last year it took them a full week just to get me an AVM estimate. There was a drive by service ordered that substituted what the appraisers used to be tasked with, which was 1075 exterior only no value reports, which was completed by a real estate sales agent, contracted through an amc, with undisclosed fee sharing arrangements. If the avm would not have indicated I had a positive loan to value ratio, they would have then either ordered some appraisal product from an appraiser, or more likely since my LTV was still positive, they might have utilized a bpo cma sort of product from a licensed realty agent as a basis for my homes valuation.
Dear legislators proposing PAVE & FAIR, please include licensed Realtor and realty sales agents in your revised regulatory proposal text, they always have the option to provide valuation services too. Come to think of it, these principals should be applied to homes in foreclosure status. Are we certain the county clerk and recorder alongside the treasurers office alongside the public trustee are operating in an unbiased manner? If the problem of bias in real property services is so widespread, shouldn’t it stand to reason that everyone involved in managing real property services should be subjected to similar if not matching updated regulatory approaches? What’s more important; a refinance, a notice of foreclosure, ones taxable amount basis?
Forgot the course approval links, national basis. There you go.
https://www.appraisalfoundation.org/imis/TAF/Resources/Courses/Course_Approval_Program/TAF/AQB_CAP.aspx?
ICE has been on a dive since March 25 2022, almost 35% stock dip. Bryan is spreading fake news and begs the question. Most small lenders have zero comprehension of cloud based global exchanges. My brethren can report first hand the struggle average refinance is having and how 4-8 week appraisal turn times (not to mention title and legal) is supply chain disaster. The operative term is and shall remain “collateral verification”. Sink you’re teeth into that and you will prosper!!
Bryan is spreading “fake news”? I didn’t spread any, let alone fake, news. Sorry statistics threw you off. The obvious goal is to get us to acquiesce (desktop and hybrid garbage). We are just weak when it comes to sticking together as a group.
Excuse me…4-8 week appraisal turn times include the EXTENDED TIME added while AMCs shop for the cheapest appraiser.
I have received multiple “fee & turn time requests” from various AMCs who don’t accept my quote. Then 2-3 weeks later, I’ll get the same request for the same property…sometimes from the same AMC, sometimes from a different AMC! The order hasn’t even been assigned yet! The AMC tells their client they “can’t find an Appraiser to accept the order.”
People need to STOP blaming Appraisers for extended turn times, as it’s not only US doing this.
>>>Plus, if the AMCs would stop fighting transparency, we would have already been able to get a change to HUD closing documents that SEPARATED the actual fee paid to the Appraiser & the fee the AMC gets! Appraisers have been trying to get that changed for YEARS & the deep pockets of the AMCs & their paid lobbyists block it every time!
I’m really tired of the same old crap being blamed completely on Appraisers.
The PROBLEM many times is AMCs.
“I have received multiple fee and turn time requests from various amc’s”
I have identified the primary problem. You should demand the amc’s stop emailing you and threaten them with FCC CAN SPAM act violations if they do not cease and desist with their commercialized emails. There is no special FCC exception for amc’s or their corny tech companies they spam mass commercialized messages through. If you answer a single quote, you’ve just established the relationship and given them permission to spam you for life. Thankfully, it’s never too late to unsubscribe.
https://www.fcc.gov/general/can-spam
https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
I didn’t say they were “spam-broadcast” emails. 😉
I block those.
That’s a pickle though because the tech companies must abide by can spam act rules too, often imposed by way of intermediary email providers.
So when you click spam on an amc bid request which comes from the big box companies like mercury, scope, appraisal port, valuetrac, regorra, and a few others, you may then deal with unintended consequences. Those consequences being that when your direct lender sends you an order, those companies may have already respected your wishes to identify their emails as spam, and the tech company managing all those potential clients, may refuse to email you further. Your lender is clueless you did not get the order notification and you lose the client. Additionally you will lose all future token and/or invite notices if a direct assignment lender wants to pick you up through those systems. That actually did happen to me.
And it’s deceptive, you may think it’s an independent amc using an independent email but those requests may simply have specific email titles but are really still recognized via metadata and sender receiver protocol to have come from a company like Mercury or Scope. For example, when you click an amc spam which originates from Scope, via your Xfinity email, xfinity then may place all your emails from Scope, regardless of which client originated the email, into spam. And if it happens broadly, which it does as many appraisers click amc emails to spam, then Xfinity cuts off all Scope emails as recognized spam to all email receivers, and they send little messages via IT and server management, and Scope is responsive and delists your profile so that they can still push mass emails through Xfinity. It is important to know that when you click spam, you’re clicking that for scope, mercury, port, and not the amc’s utilizing those systems.
So appraisers really need to get on board with demanding amc’s stop emailing us if we specifically ask to unsubscribe. I spoke at length with many tech companies over this issue, and I had even gone so far as to forward all amc spam back to their help emails. Turns out they don’t agree with the process of indiscriminate emails for non productive matters when it’s them receiving those emails, although they have no problem allowing predatory amc’s to waste appraisers time. I demanded what the FCC regulations dictate; the ability to specifically unsubscribe from any given specific company.
The choice to unsubscribe and delist from an entire platform is not an option and is discriminatory to the appraiser. We should not lose valid direct assignment work in our efforts to eliminate bothersome amc spam. I’ve spent well over a decade simply trying to get disclosure on how many other appraisers the fee and turn time requests were sent to, tech companies refuse to share. They know how many emails they are sending, and how many appraisers those emails were sent to, so why do they refuse to share this important data?
The tech companies don’t have a clue about regulatory structure either, they freely offer some tools appraisers may be unaware of, like the ability for amc’s or lenders to set appraisers names to do not use lists or even offering them the ability to control appraisers visibility on their internal appraiser directories, which of course are copied lists from the ASB actively licensed appraisers data feeds they pull from. They don’t mind if you lose all working potential because the secure platform tech companies whom deal with appraisers, their standard is simple; accept amc’s as an equivalent client base or lose all access.
All appraisers should approach these companies with a fresh start, verify your email is active, demand better user tools, and verify your profile is visible for new client acquisition. Mercury offering the ‘accept bids’ Y/N, they finally offered a simple tool. Still inadequate but at least it’s something. I would have that tool on for direct lenders, they need coverage on tough orders too, and that mechanism is a good way to find new appraisers to put on your client list. Mercury refuses to simply parse the option; accept communications from amc’s Y/N. Took them three or four years but eventually they came around, sort of. Scope now has this feature too but you need to individually email them, as the appraiser control tools on our side are inadequate and do not allow the same controls they have.
These tech companies are clearly pandering to the interests of amc’s and lenders, having all but completely disregarded the reason the secure tech relay sites were created for in the first place. Both management and staff has changed over and they firmly believe their job and company functions are to advocate for amc’s, despite resistance from appraisers. Just FYI, be very careful with the use of spam button and amc’s. I just threaten FCC complaints every time and post the two FCC links at them constantly. Appraisers are the only email users in the world whom are not allowed to unsubscribe from bothersome but still legal emails? No. There is no special exception for amc’s with FCC.
As far as getting any fee and turn time requests, sorry but those are always broadcast orders. You just probably don’t know. Because TRID is in place, and the borrower has already received a quote for appraisal services fees. The lender has already contracted with the amc to distribute the order. The amc is already actively trying to place the specific order. Why doesn’t the amc propose a fee and turn time around that existing data, and simply get efficient and save everyone time and energy, assigning appraisers direct orders? Because the amc has a financial incentive to shop for lower valuation service prices, so they can pocket the difference, not returning cost savings to consumers. You can’t get around it and if the amc has told appraisers otherwise, they’re lying. My constant response to fee and tat requests is; “If your company can’t figure out what a fair fee to propose for individual appraisal requests is by now, I can’t help you. Please remove my information from your contact lists, I wish to unsubscribe from these commercialized messages, etc.” If and amc is asking for bids, it’s fair rule of thumb to consider them as predatory companies seeking to take advantage of you and the consumer alike. When appraisers quote for amc’s, the appraiser becomes the customer.
Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is now. ALL appraisers should be SWAMPING their state representatives with calls & emails in OPPOSITION to this bill. DO IT NOW. **Remind them all that the job of a Professional Real Estate Appraiser is to PROTECT THE PUBLIC TRUST. That’s what we are in place for!
With all of the ridiculous changes proposed with “PAREA”, we know exactly where this is headed. Appraisers coming out of their “PAREA” certification will be able to start appraisal work with no supervision at all… PLUS… AMCs will be recruiting them like crazy in order to be “in house” appraisers that will do exactly as they are told.
*APPRAISER INDEPENDENCE WILL BE NO MORE**
Whether or not appraisers are “organized” under a common banner, we are still able to exert our influence on our OWN REPRESENTATIVES to fight this garbage before it’s too late.
CONTACT YOUR REPRESENTATIVES TODAY! MULTIPLE TIMES!
>>>But please, please, please don’t say anything so stupid that it will be turned around and used against us.
>>>That’s already happened with an appraiser from my state that emailed an ignorant rant to Maxine Waters about this. ?
Here’s my letter to my own representative about this Bill;
The Honorable Gregory F. Murphy, MD
U.S. Congressman, North Carolina, 3rd District
1105 Corporate Dr., Suite C
Greenville, NC 27858
Phone: tel:2529311003
Dear Dr. Murphy,
I am writing to express my deep concern for proposed legislation I have become aware of.
This legislation is being proposed by Congresswoman Maxine Waters (D-CA), Chairwoman of the House Committee on Financial Services. This proposed legislation comes as a result of the hearing held March 29, 2022, entitled ;
“Devalued, Denied and Disrespected;
How Home Appraisal Bias and Discrimination are Hurting Homeowners and Communities of Color”
https://docs.house.gov/Committee/Calendar/ByEvent.aspx?EventID=114561
You may read the discussion draft of the proposed legislation at the link above. This proposal would create a new federal agency and replace the current
Appraisal Foundation and it’s Boards.
https://www.appraisalfoundation.org/imis/TAF/TAF_Boards.aspx
I watched the entire hearing with great interest as I am a Professional Appraiser. While the issue of bias in appraisals appears to be a new issue, the subject actually began back in 2019. A hearing was held June 20, 2019 entitled ;
“What’s Your Home Worth? A Review of the Appraisal Industry”
https://web.archive.org/web/20221209130517/https://financialservices.house.gov/events/eventsingle.aspx?EventID=403835.
That hearing introduced data presented by Andre Perry of the Brookings Institute, which began the basis for actions since taken to attempt to address a conclusion brought on by the data. However, the actual data and the data collection procedure have never been analyzed to determine if the conclusion drawn was accurate and correct.
Since that time, there have been studies by Fannie Mae that have relied on the same data presented by Andre Perry from the Brookings Institute.
See “Fannie Mae; Appraising the Appraisal”
https://www.fanniemae.com/research-and-insights/publications/appraising-the-appraisal.
Since the Brookings Data has never been properly researched to confirm its accuracy, using it as a basis for other studies causes issues. The importance of this issue deserves extensive independent study before any action is taken.
In the course of my education and training as an Appraiser, I was constantly reminded that to do my job correctly and effectively, I always had to come from a position of neutrality. Remain neutral, unbiased (not for or against anyone) not as an advocate for any party to the transaction. I was taught that an appraiser is the ONLY party to a transaction that does not benefit directly and that a Professional Appraiser is in place to *protect the public trust.*
I genuinely and sincerely believe that and that is the way I have always done my job. The vast majority of appraisers do the same. No one is saying that there is never a case of racial bias in any appraisal, however if there are such cases, each state has an independent Appraisal Board to file complaints. These boards perform extensive investigations into all complaints against appraisers and take appropriate disciplinary action, including revoking their licenses when needed.
While I agree wholeheartedly as a Professional Appraiser that ANY type of bias in appraisals is completely unacceptable, I do NOT agree that creating a new federal agency is the solution. I believe that it will create unintended consequences for the borrowing public and for the Appraisal Profession, as well as cause severe changes in our economy of which mortgage lending and home buying is an important part. Previous attempts at legislation affecting the Appraisal Industry have not necessarily been complete successes. I refer you to the Home Valuation Code of Conduct / HVCC (2009) and to the Dodd–Frank Wall Street Reform and Consumer Protection Act. (2010)
I encourage you as my representative to get involved immediately. Time is of the essence as Congresswoman Waters gave the Financial Services Committee Members only 5 days from March 29, 2022 to respond to her proposal. This legislation is being put on an unnecessarily “fast track”.
Thank you for taking action on an issue that affects so many.
Sincerely,
(my contact info redacted)
Now…let’s get to work putting a stop to this ridiculous Bill.
https://www.forbes.com/sites/adamandrzejewski/2017/06/02/brookings-institution-the-progressive-jukebox-funded-by-u-s-taxpayers/?sh=2f9ebc035e53
More on Brookings; the progressive jukebox.
That’s a great letter. Let’s look at Brookings taxes too.
https://projects.propublica.org/nonprofits/organizations/530196577
https://apps.irs.gov/app/eos/
When asked about systemic racism in the appraisal industry, Andre Perry was the only speaker to raise his hand.
Exactly!?
https://www.workingre.com/wp-content/uploads/2013/10/Cost-Plus-AMC-Model-NE.html
2013, arguments for cost plus billing w/ amc’s.
https://millersamuel.com/tag/revaa/
Miller called it in 2009, state oversight of amc’s is largely clerical and they did severely disrupt this industry.
Just found this. Can anyone tell me whom ‘TROUTMAN PEPPER STRATEGIES, LLC (fkaTROUTMAN SANDERS PUBLIC AFFAIRS GROUP, LLC)’ is, and why they’re constantly monitoring these legislative points on behalf of REVAA for twenty thousand a pop increments?
https://projects.propublica.org/represent/lobbying/r/300931262
https://troutmanstrategies.com/
Let me get this straight… Amc’s pay all this money to REVAA, and then REVAA outsources the lobbyist task?
https://www.causeiq.com/organizations/the-real-estate-valuation-advocacy-association,454238569/
REVAA’s EIN number is found in the above link: 45-4238569 / Then you go here to the IRS site to research 501C tax exempt organizations for more.
https://apps.irs.gov/app/eos/
Just pop in the EIN, and there are multiple things to review.
REVAA’s 2018 tax return. See for yourself. There sure is a lot of money to be made in ‘non profit’.
https://apps.irs.gov/pub/epostcard/cor/454238569_201812_990O_2020021817154719.pdf
From the first link in this article; FAIR act. APPRAISAL INFORMATION. — The Office for each agency shall collect from the agency and make publicly available on a website of the agency information regarding the race, ethnicity, and gender diversity of appraisal vendors and contractors used by the agency or entities regulated or supervised by the agency
New requirement; Appraisers are required to use pronouns? Several 6th graders just got title charges for sexual harassment, for refusing to use another students preferred pronouns. They may go down as registered sex offenders.
https://www.ladbible.com/news/latest-teens-face-sexual-harassment-charges-for-over-wrong-pronouns-20220516
Also from the FAIR proposal.
Finance Agency, the Director of the Bureau of Consumer Financial Protection, and the head of the Federal Valuation Agency, in consultation with any other Federal and State agencies such officers determined to be relevant, shall establish a single Federal complaint procedure that provides for individuals to report suspected discrimination in the provision, management, and approval of real estate valuations, including appraisals, automated valuation models, evaluations, and appraiser misconduct.
damages to be awarded to the victim of such discriminatory housing practice shall include an amount that is not less than the difference between the corrected valuation of the property and the discriminatory or improper valuation of the property.
damages to be awarded to the aggrieved person shall include an amount that is not less than the difference between the corrected valuation of the property and the discriminatory or improper valuation of the property.
There is authorized to be appropriated to the Secretary of Housing and Urban Development $2,000,000 for fiscal year 2023 for the Office of Fair Housing and Equal Opportunity to carry out a media and education campaign to inform the public about discrimination in real estate transactions and how to report appraisers, real estate agents, mortgage lenders, and other housing professionals for alleged discrimination.
Oh yes, of course. You would not want to spend 2 million educating people on what appraisers do or how they can improve their value scenarios. 2 million dollars on an advertising blitz campaign enticing people to file false complaints on appraisers with the allure they can personally sue the appraisers for their valuation opinion differences between the appraisers value and various avm utilities. However, everyone and their mother is going to argue that zillow is shorting them and will file complaints on avm utilities too. I know I will, that’s free money just laying on the sidewalk. All you have to do is find one AVM lower than the others.
I’m sorry, what happened to the appraisal value pressure hotline? They’re institutionalizing value pressure on the appraiser by making the value opinion an indemnity.
Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
Jesus, just take me now.
Baggins for President. If you could sit in a room for 1 hour with Maxine we might get a reasonable result.
Honest thank you I appreciate that, but sadly, not even close. I’m surfing jobs boards dreaming of me riding a lawn mower for the city and actually getting benefits and a paid day off, being outside more often. Nowhere to go but up. I’m like hobo with an appraisal form over here; Need money to buy lawn mower. I have a dream. Work fell off and I’m not acclimating to my new unemployed status very well. So much for the concept of tenure in this industry.
And although I participate in these illuminating debates, I care less what politicians are doing. There is no reasoning with paid advocates. They’ve already gotten paid for the advocacy, nothing we say or do matters. Get your mind around it. Revisit the Permanent Apportionment Act so it’s more difficult for big corps to buy off the politicians. Save the frogs.
Laydeetee – spot on but you are aiming the gun at the WRONG player. IT IS THE LENDERS. You and I both know that appraiser only operate with answering machines and delete the $400 fee offers. We must step up and spit out quotes 3-4 time the offer and agree to provide product in 4-7 business days. This is simple – tell the AMC to confirm and acknowledge that the quote was delivered to the LENDER. They are the blockers NOT the poor AMC that listens to answering machines all days and never get a call back. Let’s get real here!!!!
I’m assuming that you probably own an AMC?
Fees go up to cover additional liability and possibly claims. Less appraisers higher fees for those that stay. Not sure I will be one of you!
That’s the traditional take on risk vs reward in the appraisal industry Kathy.
However, I can’t even begin to fathom how much I would need to charge to cover an increased risk point where the appraiser may be held civilly liable with possible legal ramifications associated with mandated appraiser prosecution upon the perception of ‘appraiser bias’. I mean seriously, imagine the situations.
$500k sale price, appraiser at $475k = $25k possible personal liability. Then on to a high end; $800k estimated refinance, $700k opinion = $100k. How about a simple manufactured home at $225k, cost approach tabled at $185k and no comps = $40k. So now that you’ve completed three appraisals and shouldered a possible $25k + $100k + $40k = $165k in personal liability, how much will you be charging for these services next week?
Remember, you’ll be mounting your defense while incarcerated.
There were other options available before Dudd-Fwank gave the AMC’s the Golden Ticket.
Check this out from memory lane 2008
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
No system will be perfect but I’ve tried all the AMC’s over the years and that business model is road hard and put up wet. Time for the barn.
The only system I’ve worked in that has allowed me to do my job honestly, fairly and still make a living is the VA rotation panel. This is not a get rich quick type of business but should be supported well enough to be able to say NO when it is necessary without being fired. I would highly consider the the Fed mandate a State-maintained rotation panel that promoted consistency in Appraiser Practice and reporting.
Thanks. Your reposting Marion Rhodes CG pictures, by the way. Here is another one.
If PAVE, FAIR, or any of these other things pass, we’ll update the picture with simple photo shop, replacing AMC with the Federal Valuation whatever that is called.
Well said Skap.
I pray we can keep this “bill” tabled until after November and bring some cents back to Congress.
What a CrapShow this has been… and will be if enActed.
I of course agree and vehemently want to be clear that the only way forward is that appraisers to step up and become their own advocates. We cannot and should not wait for someone else to do it, pick your heads up!
That was good Will, nice channel. Thank you. It takes a lot of courage to get out there like that, appreciated. You too Mark, your pages are more sophisticated than ever, lots of great content.
https://www.aei.org/profile/tobias-peter/
If readers of this blog will recall, AEI pushed the most important counter to the appraisers are racist slander to date. If at any point, appraisers write letters to anyone on this matter, always include the AEI document found here;
https://appraisersblogs.com/refuting-the-negative-race-bated-accusations
Thanks Baggins. One of these days we will have to set up a call and chat.
Nice, whomever put this together.
Everyone needs to stop whining about this and take a real diversity class. Discrimination exists. It always has. People are calling us out for it now. Good for them. If you check your bias at the door, you should be ok. If you feel threatened by this then ask yourself why. We need some diversity in this profession!
Well, after you are falsely accused by a petty borrower and then Maxine’s new “Equity Council” finds you guilty of not using superior sales to add value we will ask what tune you are singing then. We are already held to a high standard and they have not provided ANY proof of racism in this profession so…. have a nice day
Well actually she showed bias, and discrimination. Since Miller is white and it was based on race… it is racism. Sorry to burst your bubble. The proof is right there. You just don’t want to see it because it makes you have to look inwards and see all your bias.
What is the proof the issue was based on race?? Are you saying that anyone of a different race is automatically racist toward another?? That would be your bias, not mine.
I don’t know about you but I never cared if the borrower was white, black, yellow,tan or purple I followed the guidelines of 1 mile comparable size and style if not available then in a comparable neighborhood. No discrimination just like for like.
‘Everyone needs to stop whining about this and take a real diversity class.’
Um…. No we don’t. Stop telling other people how to think and how to live. Get out. Step off.
My dream of riding a lawn mower is coming true before my eyes. Conversation with major lender today; repeated rounds of layoffs, extreme cuts. Not a single order in my entire state in past two months, and this is a major national lender that pushed top 10 volume. Other lenders, similar actions. I picked up information on specific companies but it’s pointless to detail them.
Instead, go to google and enter this search term: “mortgage lending”, Layoffs
Then click the tools button in the top under search bar, and click past one month.
Enjoy the reading. Anyone have a tank of gas I can borrow?
Check this out. He’s actually doing it, lawn mower, and the rake. Living the dream. Denver 2022. Appraisers, welcome to your future so big corps can earn an even bigger cut. You are deemed non essential workers.