Our forms have gotten this big because of appraisers NOT doing the job right….reporting past sales within a year, using the 3 highest sales, not reporting over supply…hell not even reporting the true predominate value in the area….cheaper and faster is NOT better. It takes as long as it takes on each and every assignment. When we are under time restraints, quality suffers, and in the end they wont settle the loan for weeks later…its all bullshit so the borrower doesn’t have time to talk to another lender or maybe borrow some money from a family member. Remember, it all about “sales” to these people. They have no liability for an appraisers work…we do….!!!

I guess mainly what I’m saying is we need to have the independent ability to provide products and employee staff at our own discretion and lenders need to understand that we are capable of providing services faster better and more reasonable than anyone else if we are able to dictate what and how we do it rather than the lender.

The problem with all ‘short forms’ is that they typically do not include all the information of a long form – specifically intended to lead the appraiser and reader through the maze of USPAP compliance in the appraisal process.

While we are allowed to “limit scope” (skip steps), the client’s investors on Wall Street & overseas still want to see the words “appraisal” without qualifiers like restricted or limited scope. If it requires committing fraud to give them that, they are fine with it.

As for an AGA AMC; “Nope!.” We could limit admin fees and even advocate for C&R but the primary thing that we do (help defend appraisers against false charges or coercion) would automatically preclude obtaining or retaining a lender client base.

Another AMC is not the answer; though direct retention by lenders AND direct payment at the door by borrowers may be. Lenders already have access to the ASC directory. They have more than enough options to choose from.

Thank you Mike!

Yes we should come up with our own form and price for the product where an appraiser or staff appraiser does the inspection and we provide three sales three interior photos and no redundant data importing. No MC form. We can do it better and faster and that’s what lenders need to realize. All the hype is just hype. Lenders will soon realize that and if we are offering a product that can compete some will start using this option to have a report for a competitive price and quick turn time. They will want the most creditable report they can get for a quicker turn time and lower cost. We know what needs to be done and how to do it. We just need to convince lenders we have a product that is more reliable and better than what anyone else is offering. Fannie Mae needs to allow us to facilitate the process in a way that competes with this hybrid crap. A simplified 1004 but not a 1004P. Maybe we need to create an AMC in order to launch something like this. We can call it AGA AMC

Agree 100% (& thank you, and ongoing thanks to the admin of AB who has always had professional appraisers concerns first and foremost.).

Bingo! what so far is unmentioned: appraiser skills are bound to deteriorate, and rapidly, as the quantity of appraisals drops and the appraisal is segmented and distributed to ‘others’ over time.

From my perspective the whole argument about any appraiser benefit from being detached and not liable for bad inspection data, reduces our whole profession into nothing more than a BPO or AVM which can never be reliable. Afterall, those non-appraisal products have no reliable inspection information either. Again, inspection data is NOT the same as the data from public or MLS records. Inspection data involves the property that somebody trusted us to deliver a professional appraisal about in the first place. Let’s get this right.

Outside forces are trying very hard to make it easier to become an appraiser. Outside forces are trying very hard to reduce the need for appraisers. Outside forces are trying very hard to detach the appraisers from the reliable data we need to do our jobs. Isn’t it time for the appraisers to get on the same page and begin to offer solutions rather than letting everybody else do it? My hat is off to Mike and the other leaders in our national organizations who are not afraid to speak loudly for us. I hope this blog thread I began is helpful in that endeavor.

Greg, for every single objection appraisers, have had since HVCC we have (collectively) offered suggested alternatives that would work. Unfortunately as can be seen with both Dodd-Frank compliance and TAF ‘convenience policies’ toward their sponsors, those that think they are in control and untouchable don’t listen til they get hit with a hammer.

Have to get their attention first, apparently. The AMC system could (and should) have worked as bad as the model was. Extreme greed caused an irreparable breach of trust between all parties now.

True Mat, but original forms were designed to facilitate compliance and to give clients information deemed essential to understanding the report in a consistent location and format.

Anything ‘extra’ that is required could always be added to an addendum form before micromanagement became so pervasive.

My primary complaint about hybrid form products is the preprinted embedded language that makes them non-compliant and blatantly misleading. Look no further than FNMAs certification Number 4 on their 1004P (06/2017). That preprinted statement which may not be altered is not exactly what USPAP requires…either as an action or in a report. (& that FNMA 6+ page form is miles different than a typical 2 page hybrid).

Thank you Mat.

This is complicated, but not that complicated.

Mike, well said. Especially the part….”and takes the approach that if FNMA says something is ok, then it must also be USPAP compliant (NOT the case!).”… Many appraisers unknowingly found themselves in big trouble after 08 because of this. Some are still with us and some are not. As I stated, “Forms don’t comply to USPAP appraisers do.” If your a somewhat newer appraiser you best understand this. Completing any intended use appraisal product on whatever form someone tells you to complete it on without knowing what complies with USPAP and what does not could be read as misleading based on the intended use, etc. Compliance must be determine by you not the lender, Fannie Mae, Freddie, or any of the GSE people. Remember, they do not care they just want it and they have no skin in the game since your signature is the only one on the certification……Again, well said Mike.

It’s more than just making the decision to do or not to do these ourselves.

Since licensing, there has been one group that knowingly and deliberately cheat. They’ve been sending unlicensed (& undisclosed) people out to do the inspections for years.

Another group that scrupulously avoids improprieties and some go well beyond the MINIMUM standard imposed by USPAP.

There’s another large group as well. A group that doesn’t know what they can or cannot do; lacks the confidence to stand up to improper pressure and takes the approach that if FNMA says something is ok, then it must also be USPAP compliant (NOT the case!). There’s a lot of cross over between this group’s practices and the deliberate miscreants. Usually, because they have been taught by the non-compliant folks (unqualified appraiser; reconciler, AMC or mortgage brokers, and lenders that prefer a see no evil approach to appraisal).

When the non-compliant groups start competing on the basis of unrealistically low fees alone, then our highly regulated profession ceases to have a level playing field. Worse than that, it undermines the entire profession.

The acceptance of alternative standards by some states (that include my own) only promotes acceptance of bad practices and outright fraud. Frankly USPAP permits all the desired abbreviation of work ever suggested. It just requires that they not be misleading and have their limitations accurately disclosed. Especially since the SOW became a separate Rule rather than a part of something else. Compare the ClearVal report article on this blog (2 completed fraudulent reports only) and the FNMA proposed 1004P. NEITHER product does what they purport.

We (appraisers collectively, with regulators) stopped First American’s old Pace Pro because we caught it in time. It’s the same with other newer bad bifurcated hybrids.

Hey that’s what corelogic MLS did! Everything you may need is now a per diem charge and such.

Although I had resisted all this time, I finally did pick up an ipad and set that up. Oh god with the full screen ads popping in your face, the constant crashing, the inadequate user controls, lack of cohesion between ‘apps’, impossibly time draining requirements to sort through the myriad assembly of user reviews which undoubtedly are heavily populated by interested parties, lack of effective product search filtration in the apps stores, censorship and absence of previously gangbuster popular items and apps, the complaints of billing issues, seeing functions I know are available free ware on pc’s, now for sale from ‘developers’ on the stores, just all of it.

You know, I knew that was the deal long before I ever actually tried using one myself. We’re ditching that mobile nonsense for a quality laptop. If I’m on the highway, I’m going to hit the gas and do not appreciate transmission speed governors or billboards every 10 feet while I drive, a gas tank that goes empty every time I perform a vehicle function.

But that’s the new thing, the new economy, shuttle everything, provide nothing, profit. Service shuttling, middle managers, businesses without brick and mortar, they really did outpace every other traditional company for many years. Now that the base which people used to have as a comparative savings or honest market comparison point are shuttering and folding left and right, down with worker compensation, up with the prices and out with aggressive ads, as well as an accelerated pace of breaking up comprehensive software into per diem purchase choices. I like to hold a product in my hand. I like to pay cash. I’m not really keen on authentication and data tracking. If this is the way they’re all running ‘new and advanced technology’, I’m more happy than ever to have never really participated. It makes a good comparison point to what’s happening in appraisal because it’s directed by a similar mindset, tech nerds running the show. Welcome to the new bubble bust vulture capitalist sort of economy. There is a better way. The way where every worker matters. Every person matters. Every industry carves out fair terms. People actually shut the doors on censors and racketeers. Where contentious consumerism actually matters. I don’t know, if you can make sense if it all all more power to you, perhaps I’m simply too old these days to be able to just roll with it.

https://www.youtube.com/channel/UCaiLjnohYLdbf4Lu99v6kbw/videos

Well you would know about these issues that are difficult for mediocre appraisers to detail. Who is ‘the market’, and when and what will cause them to care and provide necessary process corrections and/or solutions? Serious question. It’s like we’re dealing with the institutional memory problem, here today, gone tomorrow, back to business as usual. I’m not so sure we should continue to hang our hat on value and analysis alone though. The experience gained from the interactions with other industry persons, personal or not, always helps build a better broad understanding of how it works, what tricks are played, identifying who’s honest and who’s not, etc. Most certainly, as just a regular origination appraiser, I’ve helped far more people with quality of home and safety and soundness compliance than I ever have with valuation correction issues. A lot of people have requested me to return when they’ve re engaged lending years later and it’s always been a tough conversation, I’m sorry you’ll be unable to specifically request me to be your appraiser this next time around. That detailed consultation where an appraiser can answer nearly any and every question about mortgage, servicing, and policy questions can be one of the most valuable functions we serve as far as individual borrowers and investors may be concerned. Cheers.

Now I’m reading and understanding these commentaries in a different light. That is helpful. I don’t think any of us here need to apologize for taking instant high alert status when appraisers promote amc’s though. These things really happened.

I think a primary point in regard to these pressing issues is that appraisers are unlikely to be as well equipped for challenging work, if they lose access to all the bread and butter routine requests.

Cheers.

Aka, the rolling suspension and revocation threads on the AF.

Appraisers whom think they’re all that with quick turns and reduced prices whom were not around 10 years ago should take a few days to read through those old lists. I think it was Kennedy whom like subscribed to all state data nationally so he could assemble one big spreadsheet on suspensions and revocations. Reading that is why I’m still so focused on detailed research and manual report development today. If including apprenticeship, I”m like 14 years without a single complaint. Some appraisers need to be more careful what they wish for and who they work with. Because yeah, report manipulation really did happen. That one appraiser lady who caught them red handed ended up on some witness protection program for life. Closed source and locked pdf was a much better privacy protection than open source xml data scraping. FNMA CU basically caused appraisers to have to have workfile retention, for life, no exceptions. What a mess.

Great commentary, this blog is really happening lately.

https://appraisersforum.com/forums/threads/suspensions-and-revocations.88400/page-218

I’m reminded of a quote from a very wealthy man. All appraisers should heed this warning.

“The less prudence with which others conduct their affairs, the greater the prudence with which we must conduct our own affairs.” – Warren Buffett

Remember 2008!….The reason this stuff is around is because no one went to prison. When people made millions of dollars and companies made billions and only paid millions in fines and no one goes to prison…well, why not do it again. The problem they are having and trying find a workaround is most appraisers are pushing back and not playing the game this time. Again, “most”.

I’m guessing most appraisers who survived the 2008 fallout either were or know someone who found themselves at their state board after 2008. I do, and from what I have heard it is not a fun experience and also very costly. One or two lost their license on seven and eight year old appraisals that they had no recall knowledge of or work file to defend themselves (5 year retention USPAP). One even claimed some parts of his appraisal was changed but had no way to prove it. Later articles came out regarding EVN uploaded appraisals being changed or altered; he said, that his appraisal was an EVN uploaded report (I’m taking his word on that). Just to be clear, bad appraisals and appraiser should be gone but not the good ones who get caught in something simply because they have a bad day or week or have no way to defend themselves for whatever reason. Who knows, this all makes no sense or logic after what happened in 2008.