Any worry about effective regulatory oversight or associated penalty has faded for just about anyone and any company involved with appraisers, utilizing alternative valuation products in leu of appraisals, basically anything to do with collateral valuation verification in mortgage lending.

Top to bottom, there is no effective oversight. The asc rubber stamps yearly reports, the comptroller follows with another generic pass, appraisal trade groups do nothing but rather are directed by the same stakeholder interests whom benefit from the wholesale dismissal of sound valuation process. The song and dance the appraisers still lingering in the gse origination realm go through is nothing more than window dressing and applied pressure to assure the lenders have the exact appraisal they need to push maximum volume through.

Consumers are on their own, and it shows in just about every market trend and inflated pricing structure out there.

Missing the IVPI proposal yet? I think it’s quite interesting to post this because the tenets which the argument were built around, are right now coming back around full circle.

https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

Remember Pan Crowleys ‘borrowers bill of rights’? Attached.

Would you call a process that scans peoples entire interior spaces, including personal belongings, shares that data with overseas companies, creates a digitized token of their real property asset under the label of a ‘home fingerprint’, and stages them for future exploitation from a myriad of different companies, exposed them to unlicensed property inspectors when they thought they were dealing with licensed professionals, them unknowingly paying additional costs so middle management companies can rake a portion of their valuation fees in secrete, just because they tried to get a mortgage loan; deceptive marketing practices? Or clear and forthright description of process? Take a dive into the world of digital currency and you may find there is an alarming similarity to digitized trading of all forms, and the new process of integrated lending origination. They’re turning everyone’s private property into a digitized commodity available for speculation, trading, shorting, and profit taking. So much for private property rights and the GLB act. If people knew their homes were being placed on the block chain. But they’d have to understand what the block chain is first…

Your comment captures the quiet dismantling of everything that once made rural appraisal viable, not just the work itself, but the dignity, consistency, and community ties that held it together.

You’re absolutely right: rotational assignment, stable panels, and C&R fees aren’t luxuries, they’re the scaffolding that allows rural appraisers to keep showing up. When those disappear, so does the incentive to serve these areas. And when AMCs funnel basic service work to unlicensed PDCs and realty agents, it’s not innovation, it’s extraction. The profession loses ground, and consumers gain nothing.

As for PAREA, I’ve seen the same story play out. A pathway means nothing if it leads straight into a system designed to devalue the very role it’s meant to support. We don’t need more pipelines, we need a profession worth entering.

Thanks again for adding your voice. The more we speak plainly about what’s happening, the harder it becomes for anyone to pretend they didn’t know.

You got that right Baggins & I agree.

You’re going to own nothing. And you’re going to like it. I don’t normally go for anti free market regulation. But for American property, we may very well be approaching a place where it will become necessary to force corporate holding divestment from residential and agricultural, limit their ability to speculate, hold property and land in such volume.

We have not had honest price discovery in at least a decade and it’s getting worse. Decades worth of patented technological development is being rolled out in real time all at once which is absolutely crushing the middle class and rural communities. Here we go again. Checking declining and oversupply boxes for the first time in a very long time. I just pushed a thousand into the void on texit, it’s not only the rural banks that could fail. Just in case.

Thank you for such a great and well informed comment. I started in rural. Still do one now and then, but that’s only possible through some of the very last stable appraisal order suppliers whom pay a standard C&R rate or near that, for every single order regardless of size, value, or complexity. The rare last remaining organizations that do not grade appraisers performance. Where being on the panel brings reliable continued order streams at consistent fees, which is what makes rural service possible.

If there were more of these companies left, many appraisers would likely have moved to rural locations by now and chosen to commute for city work instead. Then there is the automated road block again, the ‘geographical competence’ take. Automated tools which place order assignment preference based on proximity is what starves out rural appraisers and keeps urban appraisers firmly tied to high populace centers. Rotational assignment is far better.

Not to mention the issues with amc’s sending billions of dollars worth of service requests to realty agents instead of appraisers these days. Everything simple appraisers used to rely on for financial stability flows to unlicensed pdc’s and realty people instead now. Property inspection reports. Construction completion reports. Drive by verifications. No value service products. Amc’s lifted all that away from appraisers to increase their own bottom line profits. Consumers never saved a dime. Appraisal management companies specialize in managing appraisers right out of business and assuring nobody new will ever be attracted to the the gse side of the industry.

Just today in another thread a hopeful parea appraiser posted he’s not getting enough support and the program is not working out. That’s the problem with an approach like parea, it’s essentially a subsidy program. The program creates an easier pathway to licensing, in theory. But who will be able to make anything of this when they’re immediately subjected to the same market forces which drive all the other appraisers out of the gse space?

The skills needed for appraisers and realty agents to analyze and form value and price opinions are not being taught anymore. Or if they are, they’re utilized and implemented under a substantially different way. You can’t mass data extrapolate so much value in use characteristic, then translate that to workable defensible reporting to pass overly stringent underwriting and automated review process. Especially when the ‘review’ is being performed by non qualified non licensed people. That’s the problem with the modernization crowd whom insists appraisal should be a science, rather than a well informed artistic like practice where there is trust in licensing, and allowance for well informed estimates and assumptions. The science side mandates a requirement for charts, graphs, hard data. The art side places trust in professionalism and allows lee way for competent logical approaches.

Place a value on anything, it’s always possible. What is not possible is to carve out a financially sustainable business model where such time consuming data extrapolation, interpolation, logical assumptions can be formed into workable opinions to pass review muster and not go out of business under the weight of the modernized centralized model rife with third party exploitation and profit skimming. ‘Appraisal grading’. If you take rural work it’s a death sentence for most practical purposes under most amc or even non amc assignment models these days. Because of improper co mingling of amc handling fee and appraiser service fees, there is an additional disincentive for amc’s to want to pay more for competent appraiser expertise.

Appraiser performance grading is perhaps the most counter productive thing. If an appraiser is deemed good enough to be put on a lenders or amc’s panel, they should expect a fair share of work at relatively uniform fee. Then there is a more reliable work flow and base income, which is what allows appraisers to be able to provide extended coverage for rural work, which flows as quote fee rather than standard fee work. It’s nice to get out there and slow it down for a while, I used to absolutely love doing rural. It was not about maximized income but seeing the places, expanding my knowledge of ever complex real property issues, helping the people. With amc’s if you take longer or charge more, you get a bad grade, get downlisted on the tier, deranked, paid less for standard work. The appraiser ends up with no work instead. Take complex work, lose access to simple work. Demand a fair full fee for simple work, lose access to all work. That’s the amc standard model. Appraiser grading makes this possible.

Get to ride the bench while all the beneficial work flows at a discounted rate to a select limited body of top tier appraisers whom cut the most corners with outsourcing and automation. Then the appraiser gets the ‘opportunity’ to work on a rural when all the other appraisers pass the order by. This is how the best most broadly experienced appraisers go out of business and can never train anyone else, why no appraisers chose to live rural anymore. Appraiser performance grading. An integral part of appraisal modernization.

In a related way, even though the VA does not use amc’s, the presence of amc’s in the larger lending market is what causes the appraiser deserts in the first place. Nobody is immune to the damaging effects of amc’s and improperly co mingled appraisal service fees. We can now say with confidence, amc’s also play a substantial role in putting rural banking and credit union organizations out of business, harm rural communities whom don’t even rely on their services.

It’s a truth every rural appraiser sees up close. When local banks disappear, so do the relationships, the mentorships, and the boots-on-the-ground support that make lending possible in places algorithms can’t reach. Rural America isn’t just underserved. It’s being quietly excluded by systems that reward scale over substance.

We don’t just need capital. We need institutions that still believe in showing up.

https://www.linkedin.com/feed/update/urn:li:activity:7367171843343949826/

I’ve been doing this 43 years on 9/1. Fannie still doesn’t grok “rural” and, apparently, doesn’t want to. The AMC’s want to pay $350 for what I charged $1,200-$1,800 in the 1980’s. That is, they see rural appraisals as something I should do as some sort of zero sum activity just for fun. I typically tell rural borrowers to expect strange things and ask them if there’s a local lender they’ve ever done business with. During the refi boom a lender wanted the owners of a somewhat high end property with 80 acres to give up their ag exemption simply to get a loan from them!

“Regulators and lenders reported appraisal delays that extended rate locks, impeded credit, and delayed closings.” How is this on the appraiser? This is on the unrealistic and sometimes insane expectations of lenders. Many times, I’m three days into an appraisal before I can even ascertain which property I’m supposed to be appraising due to the lack of accurate information from the AMC and or lender. Then, if I ask for clarification, they don’t respond and cancel the order. Like I said.

Anyway, I love watching the lending industry whine about the lack of appraisers and turn times and costs when they’ve done everything in their power to destroy us!