IF there were a national ethical accountability board and no one turned anyone in because it would take too much of their time, what good would it do?

The Federal CFPB IS that accountability ‘board’. They took a long time to get up and running but the Executive Director of the Appraisal Sub Committee says they ARE taking complaints and acting on them now…finally. He admitted that often we (appraisers) don’t know whether we are supposed to turn one into the FFIEC OR the CFPB. IN Nevada, at the TAF/APB Public Meeting he said we can forward the complaints to him if we are unsure where to send them and while he doesn’t;t deal with them directly, he’d make sure they get to the right parties.

Send to Jim Park Jim@asc.gov  IF you are an AGA member and send a complaint to them, please send a copy to us as well and we will try to follow up on it if they fail to acknowledge receipt of it.

If I turned in every irrelevant and illogical ‘revision request’ which underwriters blindly regurgitate from XML warning points, and would never have been issued by human appraisers, I’d have to turn in the majority of mortgage lending clients I work with. AIR and XML together is like a frog in water which is just about to boil. Best thing for underwriters though, because they can literally operate asleep at the wheel, and they don’t even have to read the reports they review anymore. / Mix that up with the quickie products and avm, and lenders and amcs have created the perfect system to waste more human effort on irrelevant actions then ever before seen in this industry. The only reason they want appraisers to do the avm like quickie is because they’re officially disallowed from using the bpo or avm already. What the appraisal industry needs is an ethical accountability board, which has broad powers to deal harsh penalties to anyone whom has official dealings with state licensed appraisers, pertaining to loans sourced through either state or federally licensed lending or holding companies. To date, the appraisal industry ethical positions remain largely unrecognized, because there is no authority within this and related industries, which takes ethical violations against proper valuation process seriously. If the state ever made an outbound phone call to set a lender or order distributor straight, I’d be mighty surprised.

By the way, this is one more reason for INSISTING on copies of any “reviews” claimed by a client or AMC. I do NOT respond favorably if or when a client says “UW or ‘reviewer’ want explanation for such and such. I want to SEE the UW source communication or purported review. Changing a report based on email communications originated by unknown parties without seeing the documents referenced is an invitation to get a state complaint.

My only response if such a ‘review’ were ever presented to me is: What are the appraisers qualifications to be performing this review, and why doesn’t it meet the MINIMUM review appraisal standards adopted for federally regulated transactions? My next step would be to send it to both MY state regulators, and the state regulators in whatever state the ‘review’ was performed in.

We need to put a STOP to the use of all the exceptions to “appraisals”. TAF should be involved in this as well in my opinion. They are charged with maintaining the nations trust in appraisal and the appraisal process.

Please let us know if you are interested. We believe there is a great deal of volume we can earn over time.
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No thanks. Nothing, and I mean absolutely nothing, moves across my desk for less than $150. Desktops are 250 minimum. Drive by’s are 325 minimum. Full appraisals are 450 minimum. These ‘new products’ are merely workarounds regarding the rules they can’t use bpo’s in leu of appraisal products. And I keep on responding with the same tired old line; When an appraiser provides a valuation opinion, even if it’s merely the act of selecting comps, the normal standards rules apply. Regardless of how beneficial these products are to lenders, their implementation is at odds with existing appraiser ethics, appraisal developmental guidelines, and record keeping guidelines. To put it plainly; adoption of such a product is against my best interest as an appraiser. I will not accelerate my own demise by completing these kinds of work products. If they want a bpo, they should hire a realty person. If they want an appraisal, they’ll need to pony up. Behind the scenes, the adoption of these new tools are merely a way to redirect business expense write offs away from paying appraisers, and towards new technology which works in favor of the lender and distributor. Good for them, bad for appraisers. If appraisers are eager to put themselves out of business, I’m sure they’re actively completing these products. In just the past 6 months, I’ve seen several asset managers and other similar outfits whom seek internal valuation use services, try and adopt these products. If FNMA does not offer the form, I will not complete it, if there is even a remote chance that form will be tied, or will be used in relationship to a loan package backed by a gse loan. To put it simply; unless you are a credit union asking for a quickie product for your in house loan, it’s short sighted practice to ask for something other than FNMA forms from appraisers.

http://us3.campaign-archive2.com/?u=149bf6c78d30cb805feb29115&id=b0c3e8b118&e=e5f9ca8382

Koma: Respectfully too many of us are just ignoring them. The specific one in question is without a doubt misleading and its use as well as advertisement appears to violate appraisal laws in (at least) my state. We need to start calling lenders/AMCs/AMPs ‘out’ whenever they promote these dishonest services.

IF only 100 appraisers wrote to CFPB or ASC on this one service, do you think it would exist a week from now?

PS-if it is NOT USPAP compliant, turn the signing appraisers in to the state boards where they are located as well as the state boards where the work is performed. Some states (lie Nevada) REQUIRE that the desk reviewers be licensed in that state too. Otherwise they consider it appraisal practice without a license.

So now we find out First American owns ACI. Yup… the title and the article says it all. Thanks for the info

Note: WF has since sold Rels.

I wonder if those vendor specific ‘reviews’ are what they use to force appraisers to push values; or turn them in to state agencies when they refuse?