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	Comments on: Another Threat Looming	</title>
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		<title>
		By: Anna Richardson		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-24327</link>

		<dc:creator><![CDATA[Anna Richardson]]></dc:creator>
		<pubDate>Wed, 02 Jan 2019 11:28:54 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20170&quot;&gt;Debbie Biehl on Facebook&lt;/a&gt;.

Debbie, as in the prior banking debacle, the banks that opt for this trash are not lucid but instead are driven by greed. How many times do we need to prove that the banks opting for no appraisals are not concerned about their lending risks? The appraiser also has a due diligence to the general public.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20170">Debbie Biehl on Facebook</a>.</p>
<p>Debbie, as in the prior banking debacle, the banks that opt for this trash are not lucid but instead are driven by greed. How many times do we need to prove that the banks opting for no appraisals are not concerned about their lending risks? The appraiser also has a due diligence to the general public.</p>
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		By: Debbie Biehl on Facebook		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22134</link>

		<dc:creator><![CDATA[Debbie Biehl on Facebook]]></dc:creator>
		<pubDate>Thu, 09 Aug 2018 20:37:46 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22112&quot;&gt;Realrose&lt;/a&gt;.

Everyone has to realize that the Appraisal Institute is an Appraisal school.

That is it, except they are in business to keep everyone going to their classes or they will not be in business.

AMC’s are our direct competition and therefore competing for the same dollars we are.

I do not work for them as they take my profits.

No Lender will give money away today. Because even if they are allowed to do that, the same government who tells them they can will come back and fine them even more than they loaned.

Rumor has it that the 1004 MC May be dropped from our reports. Freddie is still deciding whether or not to go along with Fannie. These reports do not need to be this long. If there are all these reviewers ? watching over us they can put any needed documentation in themselves. Extra Maps, comps they think they need, and write an addendum to please themselves. On their own review.

Together we can have even more information!]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22112">Realrose</a>.</p>
<p>Everyone has to realize that the Appraisal Institute is an Appraisal school.</p>
<p>That is it, except they are in business to keep everyone going to their classes or they will not be in business.</p>
<p>AMC’s are our direct competition and therefore competing for the same dollars we are.</p>
<p>I do not work for them as they take my profits.</p>
<p>No Lender will give money away today. Because even if they are allowed to do that, the same government who tells them they can will come back and fine them even more than they loaned.</p>
<p>Rumor has it that the 1004 MC May be dropped from our reports. Freddie is still deciding whether or not to go along with Fannie. These reports do not need to be this long. If there are all these reviewers ? watching over us they can put any needed documentation in themselves. Extra Maps, comps they think they need, and write an addendum to please themselves. On their own review.</p>
<p>Together we can have even more information!</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22120</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Thu, 09 Aug 2018 17:54:53 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22112&quot;&gt;Realrose&lt;/a&gt;.

Trump derangement syndrome again? He&#039;s living rent free in your mind. You do understand that the last president to truly stand up to the fed was jfk right? What if I told you right wing, left wing, both wings on the same bird. No, you&#039;re only partially right. It is the consumers lust for credit and disregard for the dangers of debt that is the root cause of this. The lenders just gave consumers what they wanted and apparently they&#039;re too busy thinking about politics to be concerned with the money in their own pockets these days. Branding works! You may have missed the recent disclosures regarding how many amc&#039;s were recently identified as having been owned and created by title companies.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22112">Realrose</a>.</p>
<p>Trump derangement syndrome again? He&#8217;s living rent free in your mind. You do understand that the last president to truly stand up to the fed was jfk right? What if I told you right wing, left wing, both wings on the same bird. No, you&#8217;re only partially right. It is the consumers lust for credit and disregard for the dangers of debt that is the root cause of this. The lenders just gave consumers what they wanted and apparently they&#8217;re too busy thinking about politics to be concerned with the money in their own pockets these days. Branding works! You may have missed the recent disclosures regarding how many amc&#8217;s were recently identified as having been owned and created by title companies.</p>
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		By: Realrose		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-22112</link>

		<dc:creator><![CDATA[Realrose]]></dc:creator>
		<pubDate>Thu, 09 Aug 2018 16:38:22 +0000</pubDate>
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					<description><![CDATA[What has not been said is that many AMCs are owned by either banks or appraisers. What this waiver is all about in rural areas is to get the vote for trump because it will allow someone living in the boonies (where there are no jobs, or really low paying jobs) will be able to remodel their $50,000 crap shack into a $350,000 foreclosure once those people stop paying. There will be no new families wanting to pay $400,000 for a mini palace in the boonies because the kids who grew up there have to leave to go to the city to get a job. This is a political move to rid the banks and realtors of having to put up with the only honest person who values the home objectively. Therefore, everyone providing services to banks will become a rubber stamper until trump is re-elected, then the write-downs begin at the banks, and the foreclosures will become REO, then the new &quot;evaluation&quot; will become gospel. While all of us will be out of the business, they will have become successful in killing our profession.

That&#039;s ok, they are engineering the next bailout, so the taxpayers will pick up the tab, then the big money can buy up homes and rent them out. Don&#039;t worry, when you are elligible for Medicare, they will get rid of that, and then they will take away our Social Security, then we can all just become slaves doing AVMs or die.

Wake up people, there are real crooks in the Treasury and White House, Commerce, EPA, Energy, and all other cabinets. It looks more like the swamp has taken over the country than ever. I look forward to the day trump is arrested for his crimes which are way more than misdemeanors, they are all felonies, frauds, and some people drank the Kool-Aid, like trump was Jim Jones in Guiana, back in 1978. We are all getting punished and so when all our credibility is gone, people still have to eat, so they will whore for the banks as a last resort. 

Right now we have AMCs as our pimps who get more than we do, and there is no disclosure to us about what they profit on our license, E&#038;O expenses, data expenses, forms, experience, licensing fees, continuing education, and repeated bullshit coming from the people at TAF and ASC who have given in to the lobbyists for banks. Even our AI lobbyists are lightweights and can&#039;t do anything else but sell us out. The head of the AI lobbying is a former mattress lobbyist, and the state guy is a failed politician who didn&#039;t raise one dollar for his failed campaign in Maryland when he ran for a local office. Don&#039;t forget, the AI and other appraiser supported organizations have sold us down the river so our designations don&#039;t mean anything because they are looking for the inexperienced appraisers to do work for nothing.]]></description>
			<content:encoded><![CDATA[<p>What has not been said is that many AMCs are owned by either banks or appraisers. What this waiver is all about in rural areas is to get the vote for trump because it will allow someone living in the boonies (where there are no jobs, or really low paying jobs) will be able to remodel their $50,000 crap shack into a $350,000 foreclosure once those people stop paying. There will be no new families wanting to pay $400,000 for a mini palace in the boonies because the kids who grew up there have to leave to go to the city to get a job. This is a political move to rid the banks and realtors of having to put up with the only honest person who values the home objectively. Therefore, everyone providing services to banks will become a rubber stamper until trump is re-elected, then the write-downs begin at the banks, and the foreclosures will become REO, then the new &#8220;evaluation&#8221; will become gospel. While all of us will be out of the business, they will have become successful in killing our profession.</p>
<p>That&#8217;s ok, they are engineering the next bailout, so the taxpayers will pick up the tab, then the big money can buy up homes and rent them out. Don&#8217;t worry, when you are elligible for Medicare, they will get rid of that, and then they will take away our Social Security, then we can all just become slaves doing AVMs or die.</p>
<p>Wake up people, there are real crooks in the Treasury and White House, Commerce, EPA, Energy, and all other cabinets. It looks more like the swamp has taken over the country than ever. I look forward to the day trump is arrested for his crimes which are way more than misdemeanors, they are all felonies, frauds, and some people drank the Kool-Aid, like trump was Jim Jones in Guiana, back in 1978. We are all getting punished and so when all our credibility is gone, people still have to eat, so they will whore for the banks as a last resort. </p>
<p>Right now we have AMCs as our pimps who get more than we do, and there is no disclosure to us about what they profit on our license, E&amp;O expenses, data expenses, forms, experience, licensing fees, continuing education, and repeated bullshit coming from the people at TAF and ASC who have given in to the lobbyists for banks. Even our AI lobbyists are lightweights and can&#8217;t do anything else but sell us out. The head of the AI lobbying is a former mattress lobbyist, and the state guy is a failed politician who didn&#8217;t raise one dollar for his failed campaign in Maryland when he ran for a local office. Don&#8217;t forget, the AI and other appraiser supported organizations have sold us down the river so our designations don&#8217;t mean anything because they are looking for the inexperienced appraisers to do work for nothing.</p>
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		<title>
		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20243</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Thu, 22 Mar 2018 05:36:36 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20237&quot;&gt;Dan Frushour&lt;/a&gt;.

Dan every time its proposed it gets shot down as being impractical; or impossible depending on who you ask. Personally I agree even if it DIDN&#039;T offer meaningful protection. It might make some of the thieves think it protects the work.

You do know of course that getting two appraisers to agree to the same thing is easier said than done, right?]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20237">Dan Frushour</a>.</p>
<p>Dan every time its proposed it gets shot down as being impractical; or impossible depending on who you ask. Personally I agree even if it DIDN&#8217;T offer meaningful protection. It might make some of the thieves think it protects the work.</p>
<p>You do know of course that getting two appraisers to agree to the same thing is easier said than done, right?</p>
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		By: Dan Frushour		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20237</link>

		<dc:creator><![CDATA[Dan Frushour]]></dc:creator>
		<pubDate>Thu, 22 Mar 2018 02:20:28 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20216&quot;&gt;Debbie Biehl on Facebook&lt;/a&gt;.

&lt;p&gt;Debbie, I agree. I taught prelicensure classes in SE Mich for many years and have been suggesting for some time that our industry should collectively consider copyrighting our work.&lt;/p&gt;
]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20216">Debbie Biehl on Facebook</a>.</p>
<p>Debbie, I agree. I taught prelicensure classes in SE Mich for many years and have been suggesting for some time that our industry should collectively consider copyrighting our work.</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20235</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Thu, 22 Mar 2018 01:30:05 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20234&quot;&gt;Mike Ford, AGA, GAA, RAA, SCREA, Realtor®&lt;/a&gt;.

I&#039;m in! Theoretically this could all come back down the line through portfolio management companies like Stewart Lending Services. Would love a real job at an outfit like that, work from home of course. If the entirety of origination work falls out, companies like that will likely become busier than ever.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20234">Mike Ford, AGA, GAA, RAA, SCREA, Realtor®</a>.</p>
<p>I&#8217;m in! Theoretically this could all come back down the line through portfolio management companies like Stewart Lending Services. Would love a real job at an outfit like that, work from home of course. If the entirety of origination work falls out, companies like that will likely become busier than ever.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20234</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Thu, 22 Mar 2018 01:24:26 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20216&quot;&gt;Debbie Biehl on Facebook&lt;/a&gt;.

I&#039;ll carve out a niche helping borrowers (buyers and refis) to sue their lenders that used AVMs and took advantage of them by putting them in predatory loans they could not afford using property that can&#039;t be sold for enough to pay off the debts..

Heck, ALL the time I currently spend trying to organize opposition to appraisal abuses could be spent paring with some ambulance chasing attorneys and going after the big bucks!

Got some real deep pockets there.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20216">Debbie Biehl on Facebook</a>.</p>
<p>I&#8217;ll carve out a niche helping borrowers (buyers and refis) to sue their lenders that used AVMs and took advantage of them by putting them in predatory loans they could not afford using property that can&#8217;t be sold for enough to pay off the debts..</p>
<p>Heck, ALL the time I currently spend trying to organize opposition to appraisal abuses could be spent paring with some ambulance chasing attorneys and going after the big bucks!</p>
<p>Got some real deep pockets there.</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20231</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Wed, 21 Mar 2018 22:43:10 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20178&quot;&gt;David Wimpelberg on Facebook&lt;/a&gt;.

There are legal tracking systems for use of lobbyist efforts.  Please research this and provide evidence.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20178">David Wimpelberg on Facebook</a>.</p>
<p>There are legal tracking systems for use of lobbyist efforts.  Please research this and provide evidence.</p>
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		By: Debbie Biehl on Facebook		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20216</link>

		<dc:creator><![CDATA[Debbie Biehl on Facebook]]></dc:creator>
		<pubDate>Wed, 21 Mar 2018 03:34:12 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20202&quot;&gt;Mike Ford, AGA, GAA, RAA, SCREA, Realtor®&lt;/a&gt;.

Didn’t say it’s beneficial for us, but Who in their right mind wants the buy backs. There are no bail outs anymore.

We as appraisers are on the cusp of extinction in many ways. We pay for all aspects of our appraisal. All the software, advertising, AMCs, Pay fines if we make a mistake etc...
Then we have USPAP. The the Lender gives it to Fannie Mae to put into a data base and Fannie uses it against us

Why don’t we Copyright our work and charge the users of our work a large fee?
And those using AMCs are giving two thirds of their Fee to them.
Technology has already taken a ton of what we do, but we GIVE it to them.
Won’t need a ton of appraisers in the future.
What do you think Core logic is doing. Buying up every thing statistical and valuation related.
Titan analytics is owned and operated by Core logistic. Landsafe, and Realcomp.
Soon we will all be extinct.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20202">Mike Ford, AGA, GAA, RAA, SCREA, Realtor®</a>.</p>
<p>Didn’t say it’s beneficial for us, but Who in their right mind wants the buy backs. There are no bail outs anymore.</p>
<p>We as appraisers are on the cusp of extinction in many ways. We pay for all aspects of our appraisal. All the software, advertising, AMCs, Pay fines if we make a mistake etc&#8230;<br />
Then we have USPAP. The the Lender gives it to Fannie Mae to put into a data base and Fannie uses it against us</p>
<p>Why don’t we Copyright our work and charge the users of our work a large fee?<br />
And those using AMCs are giving two thirds of their Fee to them.<br />
Technology has already taken a ton of what we do, but we GIVE it to them.<br />
Won’t need a ton of appraisers in the future.<br />
What do you think Core logic is doing. Buying up every thing statistical and valuation related.<br />
Titan analytics is owned and operated by Core logistic. Landsafe, and Realcomp.<br />
Soon we will all be extinct.</p>
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		<title>
		By: Jack Of All Trades		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20215</link>

		<dc:creator><![CDATA[Jack Of All Trades]]></dc:creator>
		<pubDate>Wed, 21 Mar 2018 03:08:15 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20195&quot;&gt;Retired Appraiser&lt;/a&gt;.

Right on retired , I wish I could of said that I walked away from it, but the truth is I ran like hell from it, I refused to take part of that extortion from the pimp AMC’s. I told them at the time where they can shove there $200 orders at.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20195">Retired Appraiser</a>.</p>
<p>Right on retired , I wish I could of said that I walked away from it, but the truth is I ran like hell from it, I refused to take part of that extortion from the pimp AMC’s. I told them at the time where they can shove there $200 orders at.</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20213</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Wed, 21 Mar 2018 01:11:29 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20213</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20198&quot;&gt;Jason Miller&lt;/a&gt;.

For Jason; These are syndicates whom have robbed pillaged and stole from American housing systems for a long time now. Your first mistake, trusting anything a lender says. Your second mistake, thinking they are not out to eliminate the appraisal profession. Your third mistake, presuming every idiot low level distributor will not be forced through the position of their employment to falsify paperwork and make waivers routine. It takes me 5 days to think about getting started on an order, make that 6 weeks for adequate balance of time. Notice how a &#039;flexible&#039; definition of C&#038;R has been abused this way? C&#038;R could be a single day. Waivers will follow. Let&#039;s see here how easy the waiver program will really be. I&#039;ll contact 3 appraisers I know refuse service to our company or are very far away, elderly, whatever. Viola! Waiver.

Senators should wear little NASCAR style labels on their cheap suits so we know who&#039;s paid for their votes.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20198">Jason Miller</a>.</p>
<p>For Jason; These are syndicates whom have robbed pillaged and stole from American housing systems for a long time now. Your first mistake, trusting anything a lender says. Your second mistake, thinking they are not out to eliminate the appraisal profession. Your third mistake, presuming every idiot low level distributor will not be forced through the position of their employment to falsify paperwork and make waivers routine. It takes me 5 days to think about getting started on an order, make that 6 weeks for adequate balance of time. Notice how a &#8216;flexible&#8217; definition of C&amp;R has been abused this way? C&amp;R could be a single day. Waivers will follow. Let&#8217;s see here how easy the waiver program will really be. I&#8217;ll contact 3 appraisers I know refuse service to our company or are very far away, elderly, whatever. Viola! Waiver.</p>
<p>Senators should wear little NASCAR style labels on their cheap suits so we know who&#8217;s paid for their votes.</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20212</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Wed, 21 Mar 2018 01:00:45 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20212</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20208&quot;&gt;Mike Ford, AGA, GAA, RAA, SCREA, Realtor®&lt;/a&gt;.

AIR certification regardless of who signs it, is a joke unless every single person on the distribution staff are licensed appraisers or alternatively there is a senior appraiser whom calls all shots on panel. People without any mortgage, realty, appraisal, or even underwriting experience have absolutely no business being &#039;assignment managers&#039;. They&#039;re more pliable and will railroad appraisers in their ignorance without even understanding they create unacceptable assignment conditions with last minute mandates and imbalanced distribution methods. Amc or not does not matter if the assignment people are not constrained by any personal licensing and subsequent ethical principals. These unlicensed unaccountable employees will find clever ways to make these waivers happen and I would not put it past any of them to just falsify a few quick &#039;appraisal request&#039; papers and make a regular habit of obtaining waivers the easy way. The worst thing to happen to unlicensed people is they will probably not even lose their job. With no accountability the waiver program will be immediately abused from day one. But that&#039;s the plan, that&#039;s why these powerful lending groups like the waiver proposal, a wide open door for abuse of process.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20208">Mike Ford, AGA, GAA, RAA, SCREA, Realtor®</a>.</p>
<p>AIR certification regardless of who signs it, is a joke unless every single person on the distribution staff are licensed appraisers or alternatively there is a senior appraiser whom calls all shots on panel. People without any mortgage, realty, appraisal, or even underwriting experience have absolutely no business being &#8216;assignment managers&#8217;. They&#8217;re more pliable and will railroad appraisers in their ignorance without even understanding they create unacceptable assignment conditions with last minute mandates and imbalanced distribution methods. Amc or not does not matter if the assignment people are not constrained by any personal licensing and subsequent ethical principals. These unlicensed unaccountable employees will find clever ways to make these waivers happen and I would not put it past any of them to just falsify a few quick &#8216;appraisal request&#8217; papers and make a regular habit of obtaining waivers the easy way. The worst thing to happen to unlicensed people is they will probably not even lose their job. With no accountability the waiver program will be immediately abused from day one. But that&#8217;s the plan, that&#8217;s why these powerful lending groups like the waiver proposal, a wide open door for abuse of process.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20209</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 22:27:11 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20198&quot;&gt;Jason Miller&lt;/a&gt;.

Jason, Your post is very logical but its not usually that simple.

ONE email blast with only three rejections is all it takes (even if the actual order is accepted by one outside of the three rejections - it can still be canceled). So, what was that customary fee again in item B? Who establishes normal turn around times?

AMC with 48 hour turn time? OK, so that gets you 7 days BUT there are cyclical times when even a more reasonable norm of 7-10 days is not enough in an urban area. So it might bump up to a 2 week &#039;norm&#039;. That&#039;s for a non complex deal. Say it turns out to be an unexpectedly  extremely complex assignment? Fee may be ok but turn time could become substantially longer. You do 50% of the work including appointment/inspection and comp observations but now tell them delivery is going to be 3 weeks instead of 2 and they can cancel saying &quot;JACKPOT! No appraisal needed&quot; cancel and we&#039;ll send you your $75 trip fee?

Loan officers work the phones and marketing tends to run in specific geographic areas at any given time. This tends to produce slight geographic imbalances in demand. Demand spikes are not uncommon. In fact they are exactly what the AMCs; AVM hucksters and banks are contending is a shortage now.

Risk of collateral inadequacy is not diminished just because an appraisal may cost more or take longer. That cracked foundation is not going to report itself to zillow.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20198">Jason Miller</a>.</p>
<p>Jason, Your post is very logical but its not usually that simple.</p>
<p>ONE email blast with only three rejections is all it takes (even if the actual order is accepted by one outside of the three rejections &#8211; it can still be canceled). So, what was that customary fee again in item B? Who establishes normal turn around times?</p>
<p>AMC with 48 hour turn time? OK, so that gets you 7 days BUT there are cyclical times when even a more reasonable norm of 7-10 days is not enough in an urban area. So it might bump up to a 2 week &#8216;norm&#8217;. That&#8217;s for a non complex deal. Say it turns out to be an unexpectedly  extremely complex assignment? Fee may be ok but turn time could become substantially longer. You do 50% of the work including appointment/inspection and comp observations but now tell them delivery is going to be 3 weeks instead of 2 and they can cancel saying &#8220;JACKPOT! No appraisal needed&#8221; cancel and we&#8217;ll send you your $75 trip fee?</p>
<p>Loan officers work the phones and marketing tends to run in specific geographic areas at any given time. This tends to produce slight geographic imbalances in demand. Demand spikes are not uncommon. In fact they are exactly what the AMCs; AVM hucksters and banks are contending is a shortage now.</p>
<p>Risk of collateral inadequacy is not diminished just because an appraisal may cost more or take longer. That cracked foundation is not going to report itself to zillow.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20208</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 22:12:06 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20183&quot;&gt;John O&#039;Dwyer, MAI&lt;/a&gt;.

John, what shortage is that?

I don&#039;t work for AMC chump change which is what $350 to $450 non complex sfr appraisals are today.

If Refin, Trulia, Zillow, Realist, CoreLogic RealAVM, Bangalore Bob, Hyderabad Harry or Pakistan Pete, and others of their ilk are all I have to worry about then I&#039;m golden.

If banks and AMCs WANT to create the massive shortage you are referring to, then I will welcome it. When they DO want or need an appraisal, then what you cite as a reasonable $350-$450 price, and what I think should be a $650-$750 price will jump to $1,000 - $1,250 or more.

What the heck, if it&#039;s rural tack on an extra $500 to the base! With all they saved not ordering appraisals they can afford a premium.

Agree on rebuilding old lost relationships or new ones as opportunities arise but not at the cost of reduced fees.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20183">John O&#8217;Dwyer, MAI</a>.</p>
<p>John, what shortage is that?</p>
<p>I don&#8217;t work for AMC chump change which is what $350 to $450 non complex sfr appraisals are today.</p>
<p>If Refin, Trulia, Zillow, Realist, CoreLogic RealAVM, Bangalore Bob, Hyderabad Harry or Pakistan Pete, and others of their ilk are all I have to worry about then I&#8217;m golden.</p>
<p>If banks and AMCs WANT to create the massive shortage you are referring to, then I will welcome it. When they DO want or need an appraisal, then what you cite as a reasonable $350-$450 price, and what I think should be a $650-$750 price will jump to $1,000 &#8211; $1,250 or more.</p>
<p>What the heck, if it&#8217;s rural tack on an extra $500 to the base! With all they saved not ordering appraisals they can afford a premium.</p>
<p>Agree on rebuilding old lost relationships or new ones as opportunities arise but not at the cost of reduced fees.</p>
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		<title>
		By: EJ		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20206</link>

		<dc:creator><![CDATA[EJ]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 21:52:49 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20201&quot;&gt;Mike Ford, AGA, GAA, RAA, SCREA, Realtor®&lt;/a&gt;.

I do some attorney work in the form of estates and divorces and also do vacant land. There is still work for individuals wanting to know how much to ask for FSBO sales and I guess evaluations should come into play also. I&#039;ll just have to see what happens. I don&#039;t see these small banks wanting to portfolio a bunch of loans not knowing how much their collateral is worth. I&#039;ve pretty much burned all my AMC bridges over the years.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20201">Mike Ford, AGA, GAA, RAA, SCREA, Realtor®</a>.</p>
<p>I do some attorney work in the form of estates and divorces and also do vacant land. There is still work for individuals wanting to know how much to ask for FSBO sales and I guess evaluations should come into play also. I&#8217;ll just have to see what happens. I don&#8217;t see these small banks wanting to portfolio a bunch of loans not knowing how much their collateral is worth. I&#8217;ve pretty much burned all my AMC bridges over the years.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20202</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 21:25:21 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20202</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20181&quot;&gt;Debbie Biehl on Facebook&lt;/a&gt;.

Debbie, the caveats are only as good a the mechanisms for monitoring them. Make no mistake this was written for the sole and exclusive benefit of the banking, mortgage lenders, NAR, NAHB and Data/Hybrid promoters such as First American and CoreLogic. Caveats are the first things to be stripped away in the inevitable follow on &quot;clean up&quot; Bills to come. Just look at what happened to FIRREA.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20181">Debbie Biehl on Facebook</a>.</p>
<p>Debbie, the caveats are only as good a the mechanisms for monitoring them. Make no mistake this was written for the sole and exclusive benefit of the banking, mortgage lenders, NAR, NAHB and Data/Hybrid promoters such as First American and CoreLogic. Caveats are the first things to be stripped away in the inevitable follow on &#8220;clean up&#8221; Bills to come. Just look at what happened to FIRREA.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20201</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 21:19:29 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20201</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20173&quot;&gt;E J B&lt;/a&gt;.

EJ, truly sorry to hear that. I&#039;d start looking to see what alternatives are available in other appraisal work.

I haven&#039;t thought of myself as having completely giving up sfr loan work but I just realized the other day when talking to my favorite AMC (seriously) that the last sfr loan appraisal I worked on was on my birthday 2/2015. Actually it was a review.

I just haven&#039;t missed it. Land appraisals are a good alternative (make sure you charge a LOT more than you normally do for an improved property with house). Litigation work, tax work. Look into ERC (Employee Relocation Council). I guarantee THEY aren&#039;t about to stop using appraisals. They have also always paid more. Significantly more. VA and FHA are not likely to accept waivers...yet. Credit Unions may or may not. My guess is the stupidly managed (as opposed to merely being poorly managed) ones will use waivers.

Commercial and apartments may see reduced scope products. Hard to say.

EJ, this was one of those well organized efforts by promoters that was well on its way long before we ever heard about it. Most groups wanted to get by with a very visible but on the whole ineffective letter writing campaign to stop it (the letters were great but needed extra outside targeted efforts). Not enough coordination to pull it off. AI and maybe ASA could have influenced it. My guess is that the 3 million member NAR probably supported it.

What aggregator of data out there has their own proprietary AVM; national records database, owns appraisal portals and has gross revenues of about a Billion and a half per year? My guess is they were also a huge behind the scenes player...right along with ABA and MBA.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20173">E J B</a>.</p>
<p>EJ, truly sorry to hear that. I&#8217;d start looking to see what alternatives are available in other appraisal work.</p>
<p>I haven&#8217;t thought of myself as having completely giving up sfr loan work but I just realized the other day when talking to my favorite AMC (seriously) that the last sfr loan appraisal I worked on was on my birthday 2/2015. Actually it was a review.</p>
<p>I just haven&#8217;t missed it. Land appraisals are a good alternative (make sure you charge a LOT more than you normally do for an improved property with house). Litigation work, tax work. Look into ERC (Employee Relocation Council). I guarantee THEY aren&#8217;t about to stop using appraisals. They have also always paid more. Significantly more. VA and FHA are not likely to accept waivers&#8230;yet. Credit Unions may or may not. My guess is the stupidly managed (as opposed to merely being poorly managed) ones will use waivers.</p>
<p>Commercial and apartments may see reduced scope products. Hard to say.</p>
<p>EJ, this was one of those well organized efforts by promoters that was well on its way long before we ever heard about it. Most groups wanted to get by with a very visible but on the whole ineffective letter writing campaign to stop it (the letters were great but needed extra outside targeted efforts). Not enough coordination to pull it off. AI and maybe ASA could have influenced it. My guess is that the 3 million member NAR probably supported it.</p>
<p>What aggregator of data out there has their own proprietary AVM; national records database, owns appraisal portals and has gross revenues of about a Billion and a half per year? My guess is they were also a huge behind the scenes player&#8230;right along with ABA and MBA.</p>
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		<title>
		By: Jason Miller		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20198</link>

		<dc:creator><![CDATA[Jason Miller]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 09:50:26 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20198</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20196&quot;&gt;Baggins&lt;/a&gt;.

&lt;p&gt;“(A) has contacted not fewer than 3 State certified appraisers or State licensed appraisers, as applicable, on the mortgage originator’s approved appraiser list in the market area in accordance with part 226 of title 12, Code of Federal Regulations; and&lt;/p&gt;
&lt;p&gt;“(B) has documented that no State certified appraiser or State licensed appraiser, as applicable, was available within 5 business days beyond customary and reasonable fee and timeliness standards for comparable appraisal assignments, as documented by the mortgage originator or its agent;&lt;/p&gt;
&lt;p&gt;This implies, to me, that IF an appraiser is not available, THEN the waiver is possible.  If you are available and willing to accept an assignment, you&#8217;ll get the work&#8230;&lt;/p&gt;
]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20196">Baggins</a>.</p>
<p>“(A) has contacted not fewer than 3 State certified appraisers or State licensed appraisers, as applicable, on the mortgage originator’s approved appraiser list in the market area in accordance with part 226 of title 12, Code of Federal Regulations; and</p>
<p>“(B) has documented that no State certified appraiser or State licensed appraiser, as applicable, was available within 5 business days beyond customary and reasonable fee and timeliness standards for comparable appraisal assignments, as documented by the mortgage originator or its agent;</p>
<p>This implies, to me, that IF an appraiser is not available, THEN the waiver is possible.  If you are available and willing to accept an assignment, you&#8217;ll get the work&#8230;</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/rural-areas-appraisal-waivers-de-minimus-threats/#comment-20196</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Tue, 20 Mar 2018 00:52:23 +0000</pubDate>
		<guid isPermaLink="false">https://appraisersblogs.com/?p=17419#comment-20196</guid>

					<description><![CDATA[Because poor people do not deserve the same level of valuation protection.]]></description>
			<content:encoded><![CDATA[<p>Because poor people do not deserve the same level of valuation protection.</p>
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