Expert Wants to “Eliminate” Appraisers
Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response
The National Mortgage News website just published an interview with an industry expert who openly stated she wants to “eliminate” the appraisal profession. No subtlety, no nuance — she wants us gone! Given the name of the website, I didn’t expect to find too many pro-appraiser viewpoints. I ran a search for the term “appraiser” on the website’s internal search engine and many of the articles that came up were about eliminating the profession or the current state of appraisal waivers.…to “eliminate” the appraisal profession…
Rather than read the article and shrug, I decided to email the reporter who conducted the interview. I copied a number of the website’s editors and also the industry “expert,” the interviewee herself. Their contact information was available via a simple Google search, so below is an unredacted copy of the email I sent:
Sent: Saturday, December 29, 2018 11:15 AM
To: elina.tarkazikis@sourcemedia.com
Cc: teresablake@kpmg.com; glenn.mccullom@sourcemedia.com ; austin.kilgore@sourcemedia.com; richard.melville@sourcemedia.com; appraiser@pacificcoveappraisals.com
Subject: Response to 5 Questions Article With Teresa Blake
Dear Elina,
I read your interview article that appeared on the National Mortgage News Website. Some interesting ideas were expressed and I have a few thoughts:
“…The customers are looking for an expedited process; they want a mortgage process that’s like Amazon.”
The ideal world would be one in which the average borrower browses a loan on a website and clicks “Add to Cart”? According to this recent article, Americans owe $14 trillion in mortgage debt. First-time homeowners in 2018 borrowed an average of ~$220,000. That’s a serious financial burden — despite the benefits of homeownership — and perhaps should not be entered into lightly. We’ve all seen what happens when the housing and lending industry goes awry — it can destabilize the entire economy.
The idea that everything in the world needs to accelerate and be made faster is dubious reasoning at best. I don’t want bridge engineers rushing their work. I don’t want doctors or nurses rushing their work. And perhaps, dare I say it?, lenders should not aspire to give someone hundreds of thousands of dollars in the time it takes to order food through a drive-thru. There are serious, real-world consequences to that. We’re not talking about ordering new wool socks.
Certainly processes can be made better, but going too fast can create as many problems as it solves. That’s why “cooling off” laws came into being for a variety of situations. Real estate is currently exempt by the FTC, but if loans can be done in 20 minutes, maybe that’ll be reexamined.
And for the record, I am not anti-AVM. I just wrote a blog post on my experience with Clear Capital’s AVM and I can see that in some situations it would totally make sense to employ one. However, even Clear Capital’s own white paper states that AVMs are not as good as appraisers. And they’re trying to sell their product!
“Quicken Loans’ sister company, Rocket Homes, bought ForSaleByOwner.com, which to me was a very unique acquisition — they’re buying a site that lets borrowers sell their homes without a real estate agent.”
So a future without appraisers and without real estate agents? That does not sound good. At. All.
“The one problem I’d like to be able to figure out is how to eliminate the appraiser.”
Gee, thanks.
…how to eliminate the appraiser…Appraisers are not a “problem.” They are an important component of sound collateral valuation and risk mitigation. I can’t begin to tell you how many problems I have discovered either researching a property to be evaluated or visiting a property with serious functional utility or condition issues. The appraiser is the fulcrum, the pivot point, that brings together data analysis, research, property condition, site issues, and a dozen other factors in the assessment of collateral. Along with analytical data, we bring the human component that can sense the intangibles. If you’ve ever been home shopping, how many times have you walked into a property that looked good in MLS photos only to discover it was grittier and less appealing in person? Maybe even some piquant cat aromas, to put the cherry on top?
The gold standard for valuation is for the valuer to have also seen, smelled, and walked the subject property. Looking at pictures doesn’t always do it.
While I do believe the industry will morph and human appraisers may not be employed quite as often, the industry is certainly not ready for their elimination yet.
“Whether that means using drones to do the appraisal and finding other ways to be more creative…”
So Amazon wants to deliver packages with drones and the mortgage industry wants to use them to do appraisals? Do we really want the sky to look like this?
“We’re going to run out of appraisers in 10 years.”
No we’re not. While the median age of appraisers in some areas is above 50 and even approaching 60, there are many younger people trying to break into the business. I am a board member of the ASA Portland, Oregon chapter of real estate appraisers and every month we have luncheon meetings. At those meetings individuals looking to become real estate appraisers are invited to introduce themselves. We have people do so at nearly every meeting — sometimes 5 or more. They come to our meetings because they need a supervisory appraiser to mentor and train them. However, most appraisers are not taking on trainees for some compelling reasons:
1) Middleman companies known as AMCs (appraisal management companies) have systematically stripped out most of the profits the appraisal industry once had. You insert a middleman into anything and they take their cut. In the appraisal industry, the sometimes take up to half of the total fee the borrower pays for an appraisal. AMCs shop appraisal orders around for days or even weeks, hoping to get someone to accept an assignment at the lowest possible fee. This lengthens the origination process and introduces valuation issues if the appraiser who eventually accepts the assignment is neither qualified or competent to appraise the subject property.
As an example, here is an order placement problem that was caused by the soliciting AMC for a rural area valuation: I was solicited to perform the assignment for a fee of X. I told the AMC to make the fee 2X. They withdrew the assignment and I went about my business. Well, guess what? A week later the order appears back in my queue for a fee of 2X. When I visited the property I asked the homeowner if they were waiting long for an appraisal and they said yes. How does that benefit anyone?
Appraisers are far too often fighting for decent fees and therefore many appraisers cannot afford to hire someone else; there is little to no profit margin to do so.
2) Most lenders and AMCs will not allow an appraiser to send their trainee out to the property even if they have one. This limitation is also stifling current appraisers’ ability to bring fresh blood into the industry. If we could send a well-trained apprentice out to an “easy” property, it would allow the supervising appraiser to make more money, allow a new recruit to learn the craft, and allow loans to be completed more quickly as the supervising appraiser would be free to tackle the knottier valuations.
“The data is there and you have automated valuation models that have been working for years.”
The data is quite often a mess. The more I have been studying the raw data export from my local MLS and county records, the more I see how important it is to have a human being cleaning up and correcting data errors. A big part of my job is contacting agents to clear important matters up.
I do think the appraiser of the future will be a valuation analyst that is also a specialized data scientist/practitioner. Maybe one day the data will be “clean” enough and reliable enough, but we are not there yet. Not by a longshot.
For the record, I recently joined RESO to assist with data standard issues.
“Appraisers push back on using an advanced AVM, where we go out and get a property condition report.”
I don’t understand this sentence, I think it is conflating multiple issues together. Usually if you are using an AVM you are not using an appraiser. There are types of assignments known as “Hybrid” appraisals where a broker or someone else gets paid $25 or so to visit a property and take photos. Then an appraiser is supposed to look at those photos and come to a value conclusion. Well, the appraisal industry is understandably loathe to embrace this model. Visiting a home and documenting its characteristics takes a lot of training to get right. I’d much rather send my trusted and well-trained apprentice to do something like that than rely on the work of a perfect stranger who might have gotten the job responding to a Craigslist posting. Yet, oddly enough, the lending work won’t let me send my credentialed trainee.
Another problem with Hybrids is they pay the appraiser as little as $50 and the appraiser must use a proprietary system rather than their own software and MLS access. I personally won’t use a product in which I do not select comparables without a check in my local MLS. Call me cynical, but I’d like to make sure I am getting the complete market picture.
“But at the end of the day, if somebody’s taking a picture of a home and you see that there’s no structural damage to it, and it’s safe, and it’s sound, and it looks to be the same it was five years ago when it was appraised last, why do we have to send out a licensed appraiser?”
Lots to unpack here, but let me just respond with another anecdote: I got an assignment for a property that was not listed on the local MLS. When researching the property I discovered that the property was essentially a double-lot in an area where there are virtually no vacant parcels. The improvements were located all on one side and if the lot were partitioned, it would have been a corner lot that could have had a duplex built on it per Portland zoning laws. We’re talking hundreds of thousands of dollars left on the table. The agent hadn’t thought of that. The seller didn’t know. The buyer may have known that and may have been looking to make an easy few hundred grand.
Eliminate the appraiser and expect to step on more and more collateral landmines.Appraisers do more than just check if the home is there and not falling down. Eliminate the appraiser and expect to step on more and more collateral landmines. Zoning changes, external obsolescence issues not present 5 years ago might be there now, companies relocate, consumer tastes change; there are lots of reasons an appraiser might be needed to integrate many disparate facts.
Final Thoughts
Again, I concede appraisers aren’t needed for every single valuation. But the interviewee stated she wanted to eliminate appraisers. Sounds ominous. I think the interviewee has forgotten the secondary and tertiary effects appraisers bring to the market. I’ve met a number of agents who said they held the price down because they knew the home wouldn’t appraise otherwise. Yes, while some agents can try to justify a sales price with dissimilar and superior properties they try to pass off as comps, many thoughtful agents keep the eventual appraisal needed in the back of their mind. What happens when agents no longer need to be concerned with an appraisal? Irrational exuberance on steroids?
I like to think of it as trace elements needed for the human body to function properly. 65% of the human body is oxygen, 18% carbon, 10% hydrogen, 3% nitrogen. Then you have trace elements like sodium (0.2%), chlorine (0.2%), and magnesium (0.1%). Those three elements together add up to 1/2 of 1% of your total body mass. Yet, see how’d you get by without ‘em.
I think the elephant in the room with eliminating appraisers is the issue of liability. Back when banks and lenders held their own paper, it was very important the collateral supported the loan as one bad loan can wipe out the profits of many well-performing ones. If a home was foreclosed on and it sold for a fraction of the loan amount, it hurt. It really hurt. But we now exist in a climate in which many loans are packaged and sold off to the secondary market, to the GSEs. The entity ultimately bearing the risk of bad loans is the US taxpayer. Just recently Fannie Mae made headlines due to low liquidity and reserves. We are 10 years past the start of The Great Recession and these guys still don’t quite have their act together.
The US taxpayer has bailed out the lending industry time and time again. The government can only print so much money before a day of reckoning will occur.
Maybe, just maybe, critical parts of the economy should be a bit slower; A bit more scrutinized; a bit more deliberated. The appraiser is the one neutral party to a real estate transaction and rather than being celebrated for saving banks and lending institutions from making billions of dollars in bad loans on overpriced homes, they are often derided, underpaid, and marginalized.
I guess we’ll see how high this clock can go: http://www.usdebtclock.org/
Abdur Abdul-Malik on e-AppraisersDirectory.com
- Expert Wants to “Eliminate” Appraisers - January 7, 2019
- First Impressions of Clear Capital’s AVM - January 2, 2019
- Just Because You’re Paranoid Doesn’t Mean They Aren’t After You - August 3, 2018
Wow! What a fantastic rebuttal…..I would make a list of my favorite points and statements, except it would be too long….thank you for putting into concise points thoughts I’ve had myself, but have not been able to adequately explain to people. I have many realtor friends and mortgage brokers, will definitely be sharing this article!
What’s interesting is this “expert” also want to eliminate real estate agents as well as appraisers! What could go wrong?
Very well written article, Abdur. Keep up the good work.
Thanks, Tom, that means a lot coming from you. You run one of the best appraisal blogs in the country!
Abdur Abdul-Malik excellent article!
Very well written! Thank you!!!
Great article. Did you get a response? I would love to hear what kind of answer these clowns have to this
Not a peep out of any of them…
The appraisers are the only ones keeping the mortgage industry honest. They are still pushing values today. Nothing will change until we rid the business of the mortgage brokers.
Thank you! My point exactly about trainees. Trainees aren’t allowed to inspect, but some other random person can?? Makes no sense to me other than wanting to finalize the process of getting rid of the appraiser.
The restrictions on trainees really is absurd.
Fannie Mae published a reminder to lenders a couple of years ago that solo trainee field and appraisal work is acceptable if the trainee is competent and proper protocols are followed. Yet, many lenders haven’t changed their internal policies.
Most lenders still want you to comment on 10%, 15%, and 25% adjustments. Fannie Mae threw out that requirement a looooonnnggg time ago…
Isn’t obvious that they just want to get rid of appraisers with respect to the trainees. All you hear in general on a constant basis is how to get rid of residential appraisers, and replace them with computers.
Never mind computers don’t buy houses and can’t smell cat urine the minute you walk up to the house…
Abdur, it really is!! Why wouldn’t they want a trainee that is directly supervised over an untrained person???? Of course we all know the answer but doesn’t make it stink any less!
So thankful you responded to this ridiculousness
Those lenders should be told the ONLY comment is that “10%, 15% and 25% adjustment guidelines have no business in an appraisal report…or explanation”
The reason those effects linger on is due to the inadequate appraisal understanding and real estate industry specific qualifications of the technical persons whom form many of the software systems lenders currently work with. From the pay per use transmission platforms all the way through lenders and amc’s internal software programs and up through similar programs funding entities use. If you were to look at reviewing software from the lenders side of the desk it’s all pre programmed options with pre selected option boxes. Recognize this or that as a warning, or not recognize this or that, click, unclick. Programmers just copied selling guide data when they developed ‘automatic review software’ years ago, and also included every possible data correlation the 1004 form data fill options would allow. Viola! Automatic reviewer software. As usual the problem with relying on technical developers is they do not revisit the softwares as regulatory and industry structure changes, the sale of the software was already made and they’re busy with the next project. Systemic database inconsistency will inevitably accelerate at an exponentially faster rate, correlated to the volume of lenders whom use those systems more frequently and move away from full service traditional appraisal engagements.
…whereas the Appraisal Institute is only interested in eliminating residential appraisers.
Great Article!! Thank you
Fantastic response! Especially this bit:
“I think the elephant in the room with eliminating appraisers is the issue of liability. Back when banks and lenders held their own paper, it was very important the collateral supported the loan as one bad loan can wipe out the profits of many well-performing ones.”
Scary times when those too big to fail use that golden parachute called a “bailout” and cronyism to further stamp out the little guy.
Good points Abdur Abdul-Malik I would like to play devils advocate and mention that not all AMCs take up to half of the fee or refuse to allow trainees to inspect and sign reports. I know of Hybrid “inspectors” that make triple what you quote. And I’m fairly certain-not many outside of our industry are concerned with appraisers making more money. Don’t get me wrong-I am with ya in most points and I’m not for eliminating the appraiser from the equation. The writing appears to be on the wall, or at least in the trade magazines.
I counter your devils advocate with my own, as in my following comments within the article found here “Done Deal”.
“Speaking of AMC’s, I just received an order from an old client who some time back chose to start going through an AMC (Valuation Connect). The property in question (4 Br, 3.1 Ba, 2,534 sf, 4,626 sf lot), is worth in the neighborhood of around $3,000,000, and the offered fee is $500, where as per the order form, the AMC MANAGEMENT FEE is $725. Here’s to another year where the middleman wants 60% of the fee, and they want the appraiser to work over Christmas while they take time off. What a bunch of thieves.”
Many AMCs take MORE than 50%, and NOT up to.
Seek the truth.
Bill quote them $1,500 to $3,000 and I’ll drive down to SD or Poway or Olivenhein or whatever myself. They’ll have to issue a new TRID though. Do you really have guys that think even the whole amc fee of $725 is remotely adequate for E&O threshold property?
@Mark: There are exceptions to every rule.
I grew up in New York City. Not every mugger who took my money pulled a gun out on me. Some didn’t even hit me. They were actually pretty nice about the whole involuntary transfer of money from my pocket to theirs…
I read the article you mentioned and thought “someone should respond.” Thank you for taking the time to say what so many of us were thinking!
Great response! I read that article and it just infuriated me. A home is not a bag of groceries, a pizza, a new dress or even a car. Just because we want it now doesn’t mean we should
The guy who mentored me (over 20 years certified general appraiser) speculated we would no longer be in the process in the future. He started an AMC.
The funny thing is, I think AMCs are in even more trouble. A number of lenders have gone back to the direct panel relationship and AVMs will make most AMCs irrelevant. That’s why the big ones like Clear Capital are furiously working on their own in-house AVM.
I fear a lot of appraisers will be caught holding the sack when many of these AMCs go under…
I thought the same of AMCs and have left the business entirely now myself! 🙂
AMC’s are definitely in trouble.
Take a look around…..there have been 2 mergers of 4 mid-level AMC’s in the past 3 months. They are consolidating trying to stay relevant for a variety of reasons, like trying to compete with Corelogic.
I’m betting 2019 is the year Corelogic puts all the other AMC’s out of business. Then we just have to deal with them…
IF it were, then the only way that we would ‘have’ to deal with them is filing a complaint with FTC.
They’re not that stupid. I remember when Ocwen was the Big Dog. I even remember when WAMU decided to ‘grow’. Growth creates its own problems.
Imagine what will happen when the next crash hits and it turns out they played a huge part in it.
Well said Abdur, well thought out and concise but full of important information.
Where and how can the residential mortgage transaction appraiser vote to prevent AVMs and automated processes from taking away their livelihood?
Who will be making the decisions and who will be listening to the appraisers concerns in this process?
Have any appraisers subscribing to AppraisersBlogs been personally contacted yet by FNMA or FHLMC requesting their input and opinion on this matter?
Will boots on the ground appraiser input matter? This goes back to questions #1, 2 and 3.
We ‘vote’ by our actions. An entity associated with FFIEC HAS reached out to us and helped kill a threat a couple years ago (PacePro) as it was first released. A limited number of State or District regulators have also reached out on AMC legislation. I know they spoke with several different appraisers from across the country.
1. The decisions will be made in the House Financial Services Committee formerly lead by Jeb Hensarling (R-TX) and now to be lead by Maxine Waters (D-CA). Many here and from other forums have communicated with them. Regardless of your voting pin lapels color, we all need to reach out to Member Waters about our concerns now.
2. Several (over 700) appraisers have signed a survey indicating interest in sending FNMA and a few big boy AMCs a message …we are still gathering facts for a law firm that has expressed interest.
3. An appraiser founder of another FB appraisers group has (nearly single-handedly) brought down an AMC that has been abusing appraisers and laws for a long time. ALL of the things are like tossing a pebble in a pond. We can’t always tell how big or how far all the ripples will go – but we do know they are being seen.
Yes. Boots on the ground appraisers DO matter. THEY are the only ones that can lend strength to the rest of us that are no more than humble doormen to the organizations that can exert influence.
I want to sign – whatever it is, I want to sign.
But what people are forgetting is that borrowers are liars.
When they say they live in a house and you show up to a mobile home…
When they say it’s got 5 bedrooms and what it really has are 5 beds in an open loft. oh the stories we can tell but the drones cant.
When you step on the flat appearing floor that literally wobbles like lily pads on a pond from the water leak.
When you open a door to a room that the owner proudly proclaims – that’s the only room we let the (100) dogs go to the bathroom in (and the floor is crawling with …)
When the smell of an indoor grow and the black drip marks on every vertical surface.
Yep – drones gonna catch that.
Very well said !!!
wow. Very well articulated response Abdur. I doubt you’ll hear back.
Great response!!
So someone FINALLY said out loud what Appraisers have known for a while now…we are not valued for what our profession brings to the lending industry or for our position of protecting the public trust.
Thank you and a really great article ….well said and delivered. We need to stand together
Wow Abdur! Well written and well thought out. I really appreciate the time and expertise it took to write this article. Can we blast this out to appraisers, realtors and lenders?
Thanks, Rachel. I am sharing it on all my social media platforms. I think appraisers need to start pushing back more and more on stuff like this. If every appraiser took the time to chime in, maybe our voices will be heard a bit more.
Very good Blog Abdur – but who is going to see it but the people on this blog?? I posted a response on the offending article. Can we attach this blog to the article in question? These “mortgage professionals” will not even ask a real Appraiser for an opinion so what can we do to better get OUR word out?? If they need fast and quick and reliable… first pick 2 and then get the resources needed to the real Appraiser – some $$$ and some TIME.
Eric, you make a good point. I didn’t notice the comments box on the article when I first saw it. Feel free to attach my response or your own. The author and the “expert” have already heard from me. 🙂
I posted the link to this page on the article. Somebody let me know if there is any issue with that. Eric Kennedy
Eric, thank you for sharing Abdur’s article!
Erik, only you and I posted comments on the articles actual published site. ON the plus side, I’m not sure how many folks they suck into paying them $379 a year for subscriptions. I only did a 14 free trial to add to your posts. Good job btw.
Excellent article and reply to the news media. Best detailed description I have seen of the issues we face… yet again. What is the deal? Why does everyone want the buyer to rush into a home that may not be worth it and why does the lender want to throw the only protector in this transaction under the bus…The Appraiser. Kind of like biting the hand that feeds you! People don’t get it. We are talking a lousy $400.00 or so dollars for an extreme amount of information given by the Appraiser to all parties and preventing future disasters. That is CHEAP insurance in my book. What I really like is your clock at the end and the point about Realtors needing to have the concern of that appraisal in the back of their minds or God Only knows how Off the rails we could find ourselves! Consumers wake up and smell the coffee! Everyone says they are speeding the process to help consumers get into the home of their dreams, well last I checked no one wants to get into a home that is not worth it quickly. When will this insanity end?
Will be sharing this one! Thanks
Answers; Fractional reserve lending & the moral hazard created by FDIC insurance as well as a similar hazard accentuated by GSE management of packaging mortgages as investments.
When the government is involved, these kinds of things happen with systemic failure points which often get worse over time. If lenders had to shoulder their own risk, loaning their own money, having to loan the entire amount and not just a fraction before they broker loans off, they’d be much more risk adverse. That’s what they’re on about weekly at ‘The Liberty Report’ w/ Dr Paul, it makes great logical sense to me so I believe them.
Abdur, great job. Not just the post, but getting the appraisers word out. I have been posting my true appraisal experiences that deal with buyers or sellers losing large sums of money or potentially losing money to show the general public the value we bring to this industry. In many cases, it’s a matter of $100,000-200,000+. I always include a link to one of the articles back to this website and more recently have asked folks to sign the petition at change.org from Jonathan and Ryan. I encourage all appraisers to do something similar. The positive response I get from people who have read my posts is reassuring.
Fifty percent of our work deals with properties over valued by either the owner or the assessor. No big deal. However, take away the collateral verification and NO ACCOUNTABLE person can guarantee the future owner of the paper that the property is even there. This is a “no brainer”. There “ALWAYS” has to be a fall guy, and we are it. Appraiser will remain in their role until they hand it off to the home licensed inspectors’.
Well as long as we have better insurance right?
They are trying to do so now. Otherwise hybrid e-manure products would not be called USPAP compliant appraisals.
It will probably never happen 100% but much of the need for residential mortgage appraisal will vastly diminish. Remember the golden rule those with the gold rule.
The sky is falling….
I don’t know what the future holds, but I know who holds the future.
No – It can not happen. The moving of mortgage paper around the world is considered one of the highest return safest investments there is. The melt down of 2009 shook the confidence in this paper. Not even greedy lenders are that stupid. When they find a new reliable collateral verification professional WITH A LICENSE, maybe – Not likely.
D
David, it can and will happen again. A year or so ago when I read FNMA was selling off a $750 million ‘tranche’ (potentially as low as $0.05 to $0.15 on the dollar – not advertised – just industry speculation), I brought it to a good friends attention. I had naive visions of retiring and managing a whole bunch of R.E. with a friend.
In less than 15 minutes a call was made to the land of sand by his friend, to a party that normally doesn’t answer his own cell phone (or even hold it when he does). A ten-minute call ensued in a language even my phones translator cant follow before the anonymous party far away said he’d normally be interested, but he was in middle of wasting $300 million on a trophy property that was grossly over priced.
Point? Even huge sums are little more than Monopoly money to these folks. The particular gent was a significant percentage owner of a bank that was also a customer of FNMA. He could have been buying back his own banks defaulted securities for pennies…on a whim he chose not to. There was a tiny bit more to this…but not much.
Lenders order appraisals for conforming loans only because they are required at present by FHFA, Fannie, and Freddie. The aforementioned are working together to eliminate appraisals.
https://www.fanniemae.com/singlefamily/day-1-certainty
My peers are living in another world. They are so naive to see their existence since Babcock from the 1920’s as an arm of the lenders. HELLO, it is the investors that need us not the lenders. Let me see if I can explain this for the LAST time. Visualize living in a foreign country and sitting on a warehouse of currency. The only way you protect that currency is TO GET RID OF IT through the purchase of mortgage instruments. Sooooo, you tell your man in NYC, I only want instruments that have collateral verification from a licensed entity. Guess who that is? It is not Mr. BPO. Enough said.
Dave
Well said !!!
Yes David and that goes with Craig’s comments below, the investment market is reactive and not necessarily pro active. Every change has far reaching consequences and every regulation is notably reactive to the problems caused by previous changes.
“We’re from the government and we’re here to help”. Is anyone still buying that in 2019? Let the lenders do what they want, and let them fail when the chickens come home to roost. The free market will allow for self correction, if we allow the bad players to finally see their day.
A few things to ponder, from 5,000 feet up:
Some might say that the Unlicensed Collateral Valuation Entities in the 80’s did little to protect S&L’s, GSE’s, PMI’s, Investors and so on. This time, it involved land development, proposed subdivisions, commercial, hotels, special use properties and other non-residential. Quickly followed by failure of the entire S&L Industry, RTC, REO’s, declining prices. Plus, appraiser licensing and USPAP to fix the problem as appraisers were blamed.
Fast Forward about 20 years: Some might say that the Licensed and Certified Collateral Valuation Entities, now bound by USPAP, requiring Ethical Behavior & meeting minimum standards, in mid 2000’s, did little to protect Banks, GSE’s, PMIs, Investors and so on. This time, it involved Single Family Residences & Condos. Quickly followed by 2008 financial melt-down, REO’s, Short Sales, declining prices, Dodd-Frank, AMCs, PIW’s, Appraisal Waivers, AVMs. Why didn’t licensing and USPAP prevent this?
Some might ask, what was the value-added of the the Collateral Valuation Entities to the lending process, whether land development and commercial in 1980’s, or, residential in mid-2000’s, preceding these two most recent R.E. calamities? Where were the gate-keepers in all of this? Why might those higher up the food chain be looking for alternatives to the status quo, considering historical context? Some may say: what do they have to lose by trying something different than what didn’t work before?
Craig, one of the big problems has been and continues to be that lenders have far too much control over the appraisal process. Yes, there were a number of bad appraisers operating at the height of the last cycle that got worthless online degrees. But let’s not forget that some appraisers who wouldn’t hit inflated numbers were blacklisted by the lenders. The industry has worked systematically to drive out the honest and hard working appraiser and has rewarded the form-filler working for $200. It’s an example of regulatory capture.
Many talented appraisers have simply given up on lending work and just do non-lending. A brain drain is never good for an industry…
They cried this year…”What is taken so long !!!” “You need to work 24/7 for us….””What do you mean you cant get out there for 3 days !!!”….cause and effect !!!
I agree with this. First place I worked was a turn and burn. I didn’t stick around. They believed it was their job to help lender clients get loans sold. Unsurprisingly they got a lot of work too. I learned from this that it’s hard to protect clients that don’t want to be protected. Also, it’s ok to just say no. My best clients are small banks that keep their own loans in house. They pay well, provide whatever is needed, ask good questions and appreciate good appraisals.
Yeah, lenders have control they lend or they do not lend, they loan at high rates or at low interest.
A lot of the appraisal problem came from appraisal experience gained during refinancing, the information was mis-leading, RE salesmen were not as involved, wall street conscience was.
R.E. is cyclical, both anally, and for longer cycles.
We can’t go back to the lenders warehousing loans to prove their quality and then reselling those loans. That process is tooo slow for our modern economy which has access to international CAPITAL.
Appraisers have to look toward the light, keep our heads out of dark smelly places.
@craig – Ooohhh…”designated member of the appraisal institute”. Now I completely understand your post.
AI is NOT representing it’s RESIDENTIAL Appraiser members nor advocating for their interests.
Since AI had their feelings hurt when they refused to abide by the document they signed when becoming a sponsor of The Appraisal Foundation, AI has been doing their best to undermine TAF and do away with USPAP.
It’s like the kid who gets mad, takes his ball and goes home…”I don’t want to play anymore ’cause I can’t have my way.”
AI’s goal is to promote THEMSELVES and their “designated” members as the only way to hire a “professional”.
If AI can not step up and use their “clout” to fight this kind of garbage, what are they good for? Oh…yeah…They’re good for coming up with ways to put money in their OWN pocket, regardless of what their members say or need. Reminds me of the US Government.
You ask…” Why didn’t licensing and USPAP prevent this?” …as if appraisers are the ones responsible. When you should be holding lenders and AMC’s accountable for the systematic way they try to work around the ONLY PARTY TO MORTGAGE TRANSACTIONS THAT IS IN PLACE TO PROTECT THE PUBLIC.
The reason “licensing and USPAP” alone didn’t prevent the last meltdown is the same reason it won’t prevent one in the future. Violations of Appraiser Independence, personal GREED and no concern whatsoever for any effect a “meltdown” will have on the US economy or the mortgage consumer.
Lady, respectfully Abdur is ASA, not AI. Not being critical – merely slightly corrective
Aside from that, the AGA is also seeking the complete elimination of TAF, and we have never been a sponsor – though we used to be friendly with their leadership. I’m often critical of AI, just as some of their members are of both myself, and AGA. Despite that, I try to keep my criticism of them related to specific issues. They do some things well. Others, not so much.
AGA opposes TAF because their actions undermine USPAP and public trust in the appraisal process and the profession of real estate appraisal. TAF as an organization sold their souls a long time ago. They still have some outstanding folks volunteering on their Boards, but the leadership has served them, and the American Public poorly.
TAF has had nearly 30 years to get USPAP right. Fundamental principles and standards of professionalism don’t need to be changed as frequently as new car leases. An organization that claims USPAP is the MINIMUM standard acceptable in federal transactions, AND that further urges ALL to voluntarily adopt them even when not required; loses all credibility when they start teaching their regulators’ appraisal reviewers that THEY do not have to follow or even feel bad about not following USPAP. The WORST appraisal review abusers found in America today are the TAF trained ones who are being (incorrectly) taught they are exempt from USPAP even if their state laws require compliance (as in California AND Maryland). Heck, one in Maryland apparently learned it’s not even necessary to tell the truth when destroying another appraisers career. I’ve already testified in court that the one in California committed perjury.
Strange how many of MISMO’s sponsors, TAF sponsors and FNMA investors and ASC advisors are all the same people. Considering MISMO is the incestuous brother-sister relationship of mortgage bankers and monopoly seeking title companies.
It’s like TAF is the chicken coop and the roosters are all telling the foxes over at MISMO to come on over, look around and maybe have a bite or two.
Hi Mike! 🙂 If you will note, the very first word in my post is… @craig. It wasn’t intended for Abdur at all! I loved his article! Apologies Abdur…and anyone else who may have misunderstood. 🙂
Apologies Lady! I did misunderstand. My fault, not yours.
It’s all good
Thank you Ma’am!
Craig the reason licensing failed to stop the post S&L recession is that the old habit (& original proposal for FIRREA) REQUIRING 10% field review was deemed to be too burdensome for lenders or borrowers.
If you field review 10% of all appraisals a couple things happen.
1. The original appraiser KNOWS that on average 1 in 10 of his own reports will be verified and he’ll have to be able to explain everything or face very real risk of a regulatory compliance complaint.
2. A trend (even without CU) of which appraisers in America are consistently turning in problem appraisals becomes apparent. Solid data (reviews) would then already exist to make a case for their removal.
3. Far more commonly, bad or ‘not best’ practices that are not dishonest, but rather knowledge and experience derived, can be identified and appraisers can be educated before the issue become real problems. Similarly, if recurring problems are found across a wide spectrum of appraisers, it may indicate that policy problems or considerations need to be reconsidered.
Enforcement is actually incredibly easy…all it takes is the will to do so. Like the will to pay C&R fees, or assure appraiser independence. [extreme sarcasm]. Right now according to ‘big data’ each appraiser in America has a 1 chance every 8 years of being turned in for a complaint. It’s both too distant and able to be dismissed with “I can defend myself” thinking to be an effective deterrent. In a 40 year career we’d have 5 disputed appraisals? Seriously?
With 10% field review ( NOT desk review!) most appraisers would have to explain and defend 2 per month. Seems burdensome on the surface, but that would also have the effect of reducing, if not eliminating lender revisions and stips over repetitive issues.
Passing laws with no intention of meaningful enforcement is why licensing failed to prevent the TARP crisis.
Abdur, THAT is one of the best articles on appraisals I’ve read this year! (OK, throw in LAST year too). So many thoughts and comments raised in reading it.
Do loan officers and agents know that MISMO and the powers NAR and NAHB support want FULL loan automation? That means NO BROKERS as well! Not loan brokers and not real estate brokers. It’s not fear mongering. MISMO has SAID they want full automation and their tentative footprints leave no secrets how they intend to proceed with it. With IRS tax return and social security automated info gathering permissions a routine part of virtually all loans requests these days, all the liar loan packaging will also become obsolete
Amazing that MILLIONS in those ‘professions’ should be so ignorantly aiming loaded guns at their own feet.
Mike, thanks for the kind words.
Real estate is an imperfect and inefficient market. That’s how just about every appraisal textbook starts out. I am certain the whole process can be made better, but I think the human touch is needed to keep things from getting out of control.
What makes real property tangible for individual citizens in the first place is Liberty. Millions of migrants whom now call themselves Americans fought and died for the liberties many take for granted today. Our American real estate system is the gem of the world. Not because of any regulatory structure or due to any lender or money changer efforts, it is because we Americans have the ability to buy into private property and the rights which come along with that. If the goal is a perfect real estate system, citizens need to stop leveraging their properties and re prioritize their efforts to escape the yolk of voluntary usury that lenders help them impose upon themselves. There is no answer to sensible lending, because debt itself is the root cause of most estate woes. All we can do is our part, do it well, and seek to lead by example.
In historical context the overbearing pressures imposed by lenders in this modern day and age practically equate us to the Sons of Liberty. Right now on this very website we are throwing the tea in the harbor. We will not accept this burden imposed through a process of taxation without representation. I’m about to post a Gadsden flag, someone stop me before this gets out of control.
Best article of the past year Abdur, great job keep them coming.
Abdur, regarding the gouging AMC’s do to our fees, isn’t the real issue the imposition of HVCC that was implemented 10 years ago?
@Jack Kemper: HVCC does not mandate the use of an AMC. Using AMCs was the lazy way out for many institutions.
The good news is many banks and lenders are getting sick of AMCs and some are going back to a direct panel relationship (properly walled off).
What does that mean?
Of course that lady is not going to comment back… Yet again the push for automation is unmasked as an avenue to increase profits, with far too little attention paid to consumer safety and the merits of traditional labor intensive process.
They’re having a tough time getting the appraiser out of the purple category. HA! You can’t make it up. Those appraisers are in that dang purple box and we need to find a way to turn them blue. First we’ll change management, then we’ll transfer all the data, then we’ll profit. Sound familiar? Brought to you by yours truly, the managing director of KPMG.
Robotic Process Automation – How Digital Labor is Transforming Mortgage Lending Details
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Robotic Process Automation – How Digital Labor is Transforming Mortgage Lending Presentation
Also, read every word of the article and comments. What a stellar letter and response set. Thank you.
Bravo Abdur. Extremely well written and thought out. Couldn’t agree more with your responses given
Very well said! I’m currently going through the trainee process (I’m in my 30s so you’re right about us breaking into the business!) Thank you for highlighting how incredibly frustrating the process is. In my area the trainee is “only required to be supervised on the first 25 appraisal inspections” which is a complete joke (as you know) because no lender will let me inspect without a supervisor. So looks like my supervisor will be along for the ride for all of my 190 trainee-required appraisals. Yet they’re toying with the idea of sending someone with no training and no related schooling just to save $$!!??!!
Don’t get ahead of yourself, there is more to it than a checklist.
I apprenticed for almost 4 years w/ my parents whom ran realty, appraisal, and a small building outfit for a time. I’m for strict non negotiable supervision through a 3 year plus apprenticeship period with less emphasis on individual workfile hours. There is plenty for an apprentice to do if only the supervisory appraisers were actually doing their job and not outsourcing essential duties, clearly not caring if distributors are compliant with FDIC guidance on appraiser selection. Who reads all those laws and regulations in this industry anyways, certainly not the appraisal management companies or the next non licensed ‘manager’. There is no central repository of essential data and regulation for appraisers. The only managerial people you can trust are the persons whom actually hold an appraisers license, the rest of them are just pretending or possibly are somewhat trustworthy clerks.
Apprentices should have to take quizzes on like 10 different government regulatory structures first. Just knowing cash flow analysis, paired sales, how to fill the form, clearly not enough. Raise your hand if you’ve read the entirety of; firrea, dodd frank, cfpb interpretive rules, state rule books for all 3 major real estate disciplines, the selling guides for hud fnma and va, kept up with all news publications, read relevant content of the federal registry, reviewed pertinent fdic guidance, irs publications, and what else… I forget being the proverbial new guy, that’s why I hang on every word from more competent senior appraisers. Considering that mindset will help you understand how easy it is to immediately discredit and ignore the automaton peanut gallery.
My step dad he said, “The lender people always give themselves fancy titles, but they do not have licenses.” My mindset is to be worthy of the license and to never abuse that trust. Only a person with a license can effectively manage an appraiser, the rest of them are just clerks.
If there were financial repercussions for mortgage brokers, loan officers, CFOs, COOs, CEOs, real estate brokers, and real estate agents when financial losses are incurred through foreclosures and short sales in residential real estate, appraisers would be highly valued in the mortgage industry. And highly experienced and educated appraisers would be the most sought out and compensated based upon their level of experience. But that is not the case and hasn’t been for a very long time. And the mortgage industry doesn’t look like they are going to move in that direction anytime soon. Appraiser’s have zero influence within the mortgage industry where short term profit is of the utmost importance and the risk is passed on to investors and taxpayers.
Let them fail. The moral hazard in mortgage lending is arguably created by the governments presence and subsequent array of insurance protections. Coupled with the Holder Doctrine, it’s essentially legal and risk free for many originators and servicers to defraud consumers. Even if they receive fines, they merely calculate that against profits and often are allowed to even write off fines as business expenses. This of course has accelerated such irresponsible practices as automation of essential human labor intensive processes. Participation levels are rising. Personally I’m surprised the appraisers eo industry has not reacted to such risky practices as hybrids, automation, and utilizing outsourced labor. They should be asking such questions on yearly renewal and charging steep premiums for such activity. One speculates that the appraisers insurers do not have to take such steps because they are either successful at shielding those appraisers or perhaps have successfully denied all coverage and those appraisers have taken the risk and liability without a safety net. In this reactive industry there are thousands of appraisers who’s ticket is already up, they just have not been notified of that yet. As 1099’s dealing with some of this countries largest and most aggressive corporations, appraisers do not need to apologize for adhering to manual traditional labor intensive processes and charging a traditional full fee. Such activity is beyond justified and those seeking to change this part of the process are completely out of line.
Absolutely right Tom. Makes me wonder if we are fighting in the wrong forum by limiting ourselves to U.S. Regulators. Perhaps we need to start directing criticisms and disclosures of the systemic weaknesses directly to the international investors that have long seen U.S. real estate securities as some of the safest investments in the world…backed by the full faith and security of the United States Government itself….or at least the taxpaying peons that comprise the United States.
@Tom Molinari: Spot on. There is an extreme moral hazard going on in the lending world. It’s been there for a long time and has gotten worse with mortgage securities and the influence of GSEs.
Agree 100%. Though calling it an extreme moral hazard politely understates the extent of the problem. I’d probably rephrase it and say “The corruption and flagrant dishonesty is so bad that some sons of bitches should be charged under RICO, and put away in jail for life!”
@Mike: LOL, tell us what you really think.
I’m being very serious Abdur.
In the 19th Century, scoundrels (often bankers) would be tarred and feathered and run out of town on a rail, subject to public humiliation the whole time. Or, alternatively, they might be shot or lynched for their misdeeds.
In the 20th Century, we became more civilized. We (largely) ended public punishment, and crime soared.
The federal government also started a practice of fining banks and institutions rather than punishing the responsible miscreants personally.
The theory was that investors would not long tolerate crooked leadership once it started costing them money. From the feds perspective, the fines covered costs of investigation and ostensibly reimbursed those that were defrauded …though the latter has been largely lost in the modern process.
Apparently, that theory doesn’t work. Not with taxpayers acting as guarantors against loss by those same investors that now demand higher returns at any cost.
Once personal responsibility was removed, financial crimes skyrocketed. Look at Wells Fargo’s record over the past 20 years alone. Seems like they get huge fines just about every other year. Yet it hasn’t been enough to change the methods of operation, no matter how much they advertise their self reinventing. They are by no means alone.
Up until very recently, the primary purpose of mortgage companies was not that they could reach more potential borrowers. It was to package borrowers or ‘sanitize’ them so that they could qualify for loans they might not be able to get from a bank.
Anyway, I can’t summarize all the conditions that lead to and are reported in “The Big Short” here. My point is that they are ongoing. Nothing has changed except the sophistication of the schemes being perpetrated.
Keating and Madoff were exceptions to the rule. Most CEOs get away with ongoing & systemic corruption. The ONLY way that will stop is when CEO’s; Board Chairman, and in some cases entire Boards start being criminally charged and sent to jail for very long periods of time.
Just like any other bank robber would be.
Great article! Thank you for representing our feelings. Based on my experience which includes appraisals performed and my own purchase and refinancing of properties, it takes the bank 3 to 6 months to finalize a mortgage application, start to finish. It takes approximately 5 to 7 days to complete a full appraisal. Want to provide the public with speed, lets eliminate banks. So where’s the logic in eliminating the appraisal profession?
A return to private silver contracts between neighbors? Dare to dream.
Great post/response Abdur. Very informative and very well laid out. Thanks for taking the time to put this out there and shed more light about the important role of real estate appraisers within the world of lending and beyond.
Thank You
Great article. I’ve always felt that doing FNMA mortgage appraisals was a lot like being the doctor on an NFL team. There’s conflicting interests. Your profession requires you to protect your patients, but your employer wants the concussed player on the field.
That’s a great analogy.
Wasn’t it just a few years ago that these same ‘industry experts’ blamed the “housing crash” on appraisers? I have performed 100’s of forensic GSE reviews on appraisals from that period and the vast majority of the values were sustained based on the contemporary data. The loose lending parameters (125% mortgages) and low interests rates drove up prices to unrealistic levels. The sales data was there to support value BUT how did those inflated prices get to that level. I guess I missed the point, the first one to pick out a scapegoat and scream the loudest seems to get the most traction in the blame game. We did get that marvelous tool known as the 1004MC to use as a crystal ball. And then there is the outright theft of the appraiser’s copyrighted data through the UAD system. So now they want lend $100,000’s without inspections. Boy would I like to take them around for a week in New York and show them a few interior inspections. Isn’t this all supposed to be about accurate valuation not check boxes and 0’s for no adjustment.
I’m rambling, sorry. Well done Abdur.
Long posts are appreciated, I try to read all of those for articles of interest.
You touch on an important point, appraisers do not perform cash equivalent analysis based on the actual rate of individual loans… If that information was disclosed the credit verification companies would have to find a new line of authentication questions and the process may open up more cans of worms than it closes. But more importantly, the fed would not be able to play god with housing prices and gdp by merely ‘adjusting the rate’, driving markets up and then down in an infinite cycle of fleecing the consumer and pandering to their insider partners.
Mr Ford’s article from today has provided for interesting new word choices. It’s important to keep the worker bees busy keeping up with a continued stream of regulatory and changing industry process catch up duties, or we may begin to question why we’re not looking at cash equivalency and then naturally take note of apparently unchecked market inflation as the dollars continue to roll off the printing press. Chicanery indeed.
Not rambling at all. Well said.
@Jerry Record: As Baggins and Mike said, we appreciate your thoughts. This is a forum for all of us to weigh in. And you make very good points. Very easy to blame appraisers when there are macro economic, fiscal & monetary policy issues all intersecting and interacting.
What’s also not given a lot of attention was the blacklisting of appraisers that occurred during the height of the last boom. Some appraisers WERE sounding the alarm and their opinions of value were below contract price. For their honesty they got put on “do not use” lists.
@Abdur – They still are being put on the “do not use” lists. 🙁
@Taunya, sad isn’t it?
Taunya, that is one of AGA’s specialties (Specifically, Jan Bellas). Assisting appraisers that have been improperly placed on do not use lists…both current and as far back as ten years ago in some instances. We also try to prevent it from happening when we are notified early enough in the process. Success rate has been very good. Not perfect, but so fare very, very good. http://www.appraisersguild.org
To steal a quote from Mark Skapinetz; “It’s like car insurance. You may drive all year and not need it. Then again, when you do need it, you REALLY need it.” (or very bad things can happen).
Having tried to communicate with GSE personnel I can tell you they are totally out of touch and arrogant while they are at it. I did an historic (~2013) forensic review for FNMA (through an AMC) for a Jan, 2009 appraisal that was funded in Mar, 2009. Keep in mind this is six months after the sky fell in. Within less than five minutes, I knew there was something wrong. Without going into too many details, these thieves signed a deceased appraiser’s details, used interior photos of a renovated two family house (not the SFR subject) and pocketed more than $600,000 in mortgage proceeds on a $280,000 investment. Who knows how many more of these they pulled off?
Ahhh, the watchdogs are on the case.
Wow, can we read about that one on the DOJ or FBI sites?
A few years back I did a single review for an amc. Appraiser dude gave same standard units highly varied Q and C ratings which did not make sense, applied an illogical spectrum of adjustments, etc. I cleaned it all up and reworked everything. Then best of all, his included EO insurance appeared to have photoshopped effective dates, and was noted as a 6 month policy. Correct me if I’m wrong but I don’t know of any eo insurers that issue 6 m policies. The amc lady would not tell, other than to say it was one big old major mess.
One can only begin to imagine the trickery that will soon enough be applied to purely eval products run by tech nerds without licenses and no personal accountability, concerned about maintaining their proprietary engagements with aggressive lenders. I can see it now. My eval is better. No mine is! Waa waa, me first, I have to feed my familyyyyyyyyyyyy!
Jerry, one of AGA’s members is a former FNMA staff reviewer. He also has many stories of inside the walls wrongdoing. I’m wondering if there is some way the two of you could be put in touch with each other where both would feel comfortable talking to the other? If interested and have any thought or ideas on it, pls email me at mike@mfford.com
Having worked in an assessor office, I can swear to the massive inaccuracy of county records in CA. If it was not built in the last 10-15 years and especially if it was built before 1974, it may be grossly wrong in data. I find especially that assessor office and permitting authority rarely if ever have shared information and almost always have an inter-department or inter-jurisdiction squabble or outright hostility which leads to zero communication regarding modifications or construction/addition/change to a property.
Also – every MLS local refuses to allow the assessor office access so that when there is a sale, there is no data on the transaction available.
There is zero way a min wage college kid or even better, a realtor can from the street, determine any true facts about a property in the time it takes to shoot 3 pictures from the moving car.
Oh, and im only talking properties in town on city sized lots.
lets totally ignore the house that the owner believes strongly in “trespassers will be shot, survivors shot again” as well as firmly thinking that no gov agency has any right to “my business” and is for darn sure not going to get a permit for the well constructed superior 5,000′ addition with gold plated everything(a little out of character but lets exaggerate shall we for effect)
And let’s let a robot try to deal with a 2/1 of 750′ on 16 acres close to town with water rights which actually happens to be a 3/1 of 1400′
or the sale that was 20k high in a model match area with brand new selling for 15k less, until you walk in the garage and find the 40 pounds of pot assumed included in the sale…
on second thought – we dont need appraisers doing inspections.
Mike, great post and confirmation of what many have known all along. You provided a highly credible explanation of why AVMs can NEVER work in California.
I’m shocked to hear mls refuse assessors access. Is that a NorCal thing, or??? Even IRS buys 50 CoStar licenses a year for its Large Business & International Division so that they can accurately appraise C&I, land, apts, etc.. Many if not most agents also contacts on outside where within the guidelines of taxpayer privacy, they can get both a subject mls history as well as anything around it. (For example, they can’t ask me for a copy of 123 ABC Street mls, but they CAN ask me for all mls on the 100 block of ABC street that listed or sold in a given period.
How come assessors offices don’t adopt similar reciprocal ‘policies’? Non-disclosure NEVER helps taxpayers or the public. On property tax issues, there is a right to know because property taxes are a PUBLIC matter – not a private issue. The mls or old timer agent thinking of “It’s MY data, and you can’t have it” never protected anyone’s market, nor benefited a typical seller.
The ONLY people it ever benefitted (non-disclosure) were folks with complex transactions designed to defraud the public by deceiving the taxing agencies. The structure of the old ARCO Towers sale decades ago was an example of that type corporate tax avoidance.
Anyway, your examples are exactly why CoreLogic’s RealAVM, Zillow and all the others will never be able to provide consistently reliable, credible value results. Aside from bad data, they don’t know what ‘value’ even means. Define it? Pffft! I’m impressed they can spell it.
Out of the 9 counties I do work in, 9 refuse MLS access.
Some counties will provide a list of transactions for a book and/or page for a fee in person at the office.
A majority of assessors systems are grossly out of date. 2 counties just went digital internally and the system they are using was created in the 1990’s and is DOS and the update scheduled for 2010 never materialized.
They participate sometimes in Parcelquest depending on county and upload data nightly. HOWEVER… if you have a multi-res property – the GLA and bed/bath count are bundled. so 4 1/1 tiny shacks looks like a 4/4 and 2400′ GLA on CR.
Locally – corelogic owns the MLS, CR (Realist), and Total.
So – where do you think all the data you have sorted and figured out is being mined and re-sold?
How much did you get paid for rolling over for free data delivery, I mean UAD…?