Not far fetched at all. FNMA has already said they take the lenders word for ht evalue on PIWs. Not much of a stretch for them to give borrowers a questionnaire asking if house is (a) perfect, (b) near perfect (c) reasonably close to perfect, or (d) just a bit better than average, (e) OHER; “will be near perfect once we get the loan for the remodel.”

Absolutely agree Rose. Two years ago when it may have done some good, appraisers could not send out their own trainees WHEN WE DEEMED them to be ready to inspect property.

Now, hybrids with pre printed text claim third party inspections “We deem to be reliable and credible” are perfectly acceptable.

All along the real problem has been that USPAP compliance is not convenient. It’s pretense can’t be abandoned outright though. TAF needs to preserve the illusion that it still means something.

Great point.

Darrell, What are the two Extraordinary Assumptions you are using, to make these products “USPAP Compliant”? I ask because EAs can only be used if they are credible, and Credibility requires support, either by relevant evidence or logic, so I’m trying to figure out how credible an EA is that takes information from an interested party, the client, and applies that information without any ability to verify that information, or have a logical reason for why you did not inspect the interior, when anybody who wasn’t you was engaged to inspect the interior. And still, you can find USPAP compliance with not turning down the report that limited your scope of work to such an extent as to impact that credibility.

So short story, What are the two EAs you use?

Darrell now you are just talking out your ass.

I used to reject 38% of all drive by requests because their was simply insufficient data. Add anther 10%+- after the driveby confirmed improvements were not even visible.

Anytime you want to discuss competency, you be sure to let me know.

I have to assume you aren’t an appraiser or you’d never make such an asinine statement to begin with. No wonder you think USPAP advocates are mere lemmings.

Then Los Angeles county has an exceptionally high number of incompetent appraisers if that’s the case. IMO

Darrell you can come to a reasonable ‘comp check’ guesstimate. If that’s all the clients need, then lets call them by that name instead of “appraisals.” In Los Angeles County, fully 40% (or more) properties will not be suited to this.

Supported or credible? Not happening.

K, USPAP IS pretty clear. It doesn’t take reading any way other than it is printed to understand.

Its NOT the AMC or so called “UW” that is the concern. It is the ever increasing number of state regulators that don’t know the difference between a FNMA Guideline and a USPAP standard Rule.

USPAP says perfection is not possible – nor expected. Regulators do not (universally) agree. Show imperfection and you are also automatically violating ethics provision and competency requirement.

Look at Oregon – fail to deliver report on time and coerced consent to multiple violations results. Oregons Board is reportedly not lead by an appraiser.

USPAP says that the sole measure of USPAP compliance is what ones peers would do in similar circumstance, and reports are to be considered in the context of the clients intended use.

Show me ONE state that uses qualified peers to review complaints. I SUSPECT New York and New Jersey follow USPAP; Virginia MAY but I simply don’t know. Maryland does NOT. Reports are that Illinois does not – though my mind is open on that one still. Minnesota does not, and further uses incompetent reviewers in house. As noted above, Oregon doesn’t even know USPAP let alone follow it. The same with California. (That ASC rates them excellent after many years of failing ratings indicates systemic rating deficiencies at ASC – not that they are competent in Cali.

In fact, California BREA tolerates outright perjury by senior state investigators in sworn testimony (names and dates available on request).

K, their is systemic corruption of FIRREA/USPAP and Regulatory compliance processes. Not primarily the integrity kind of corruption, but rather the whittling away of sound practices over too many years to adequately perform the functions as originally envisioned by Congress.

Then of course, there is the other more insidious corruption on state levels among far too many states to say the People are being protected anymore. As a percentage of the whole, I bet there are far more corrupt, dishonest and or incompetent  regulators than there are appraisers.

…and THAT is unacceptable.

Ego radar alert;  what if the ‘inspector’ is an ex con or someone whom could not get a real job?  Who gets a driving job only taking pictures that pays well?  If that job is available I want to do that instead of appraisal.  The spirit of ethic is universal, to maintain a high level of trust.  Keeping secrets about the details from the professionals we engage with is typically not a trustworthy action.  Data validation and confirmation lines appear throughout all fnma forms.  Justify the secrecy behind lenders not sharing data for their own exclusive not to be named publicly ‘inspectors’.  Also, per my above, cover the advocacy question as well.  Parsing the language of living documents is different than following the intended spirit of ethic.  Some people justify dishonest practice, others stare it down and don’t care what a tough to reach detailed interpretation of the book says.  If you can’t explain compliance simply you’re doing it wrong.  An appraiser should never be asked to rely on an unnamed inspector for volume desktop products.  That’s clearly an unethical approach unless you can specifically justify the need for such informational with holding.  The burden falls on the client, not the appraiser.  Game over.

I regrettably don’t do them at all anymore because there is so much data in the market I am in that the client no longer orders those report types and anyone else who orders them requires I use their software.  No thanks.

I think most of you need to question what you think you know about USPAP and give it a real read again.  Break out USPAP and read it along side your report.  Standards 1 and 2 actually outline a 1004, 1073, 2055, 1075, if you can believe it.  Aside from scope of work requirements and disclaimers and disclosures these forms are actually sufficient to achieve USPAP compliance.  What you are doing wrong, and therefore what you are ALLOWING your regulators and clients to do wrong is reading USPAP through poop stained goggles. You read it like “Can it be said the appraiser DIDN’T do this?” When instead you should be reading it like “Can it be said the appraiser DID do this?”

So many people fail to understand that it is the nature of humanity to be exclusionary, discriminatory, and judgmental because it is the nature of our egos – which are designed to protect us and set us higher than and apart from the rest – that causes us to be this way.  This is why letting go of the ego is enlightenment.  Can you let go of your egos long enough to read USPAP for what it is?  A simple set of guidelines rather than a mythologized, hocus pocus, misinterpreted, waking nightmare of some failed church lady or accountant – aka an underwriter.

Did you receive a request for a desktop review of a hybrid desk top appraisal???

Or, am I misreading your post?

The conversation with them goes down exactly as it would with an amc. Some lenders pay more, others less. There is separation from loan production technically, if you call lender employees in the office down the hall from the origination staff separation. People need to understand the distribution head positions are mainly populated by people who could not get jobs elsewhere. In the past few years I’ve worked with ‘panel managers’ whom; previously lost their appraisers and/or mb licenses, could not qualify for mb licenses, did not pass licensing testing, persons whom would otherwise be in HR positions, and others whom would call a move to some other part of the company a promotion. All these rules of separation are complete fails. I want to call the lender mb’s up directly, nobody else comes close to their level of expertise. If you call them you’re told they have no control at all and are basically directed by the company owners. As if the company owner will make less biased decisions than the origination staff. If we’re to keep up this farce which is separation from loan production we should move to the ivpi proposal for a government clearinghouse, force all distributors to have licenses themselves, or simply remove this errantly applied criteria. The reason nobody hires the obviously qualified person for distribution positions, the appraiser, is because they don’t want it to run correctly, they don’t want actual compliance, just the illusion of it.

Too add to that, wouldn’t it be interesting if in the process of subbing what is supposed to be the appraisers duties out to other people, the lender captures business expense write offs instead of the appraiser. Perhaps that’s why appraisers are not allowed to know who’s performing these other ancillary duties, we might not respond so well when we learned the persons picking comps, taking photos, and inspecting houses are underqualified employees of the lender. Cut to the chase then; Is it allowable for the appraiser to rely on information from advocates of the client? Also, because it gets better, how much additional write off margin do you think lenders could capture if each 700 consumer appraiser fee only paid less than a hundred to the appraiser, and instead resulted in 600 dollars worth of employee write off expenses? Call some of the ‘direct’ assignment people, you’ll find out they’re on average less qualified than many amc employees. I’m putting my bunny slippers back on, this industry is rife with unethical conduct and piss poor business decisions on all sides. If one thought hollywood attracted bad people they must never have spent a day in real estate. American values and the golden rule seem to be absent in this industry, what a shame. I continue to advise people to own homes completely and get out of mortgage lending at their earliest possible opportunity.

You know I love ya, but you’re confusing me.

AMCs are agents of the lender as mandated by decree of the banking regulators (OCC, FDIC, blah, blah, blah).
The AMC Final Rule states;
If these regulated financial institutions use an AMC to engage appraisers on their behalf, the AMC must be acting as an agent for these institutions

https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies#citation-75-p32667

If lenders are servicing other lenders as AMCs, there is no regulation against that; and being their business is “lending” they are not going to be subject to the AMC final rule as implemented by states – if they are Federally Regulated banking institutions. It is an interesting scenario though, what you post about this, as lenders should be in competition with each other for borrowers, not servicing their competitions accessory needs.  Almost makes me wonder if there isn’t any competing lenders involved in this and maybe it is something the FTC should look into?

HA HA HA

But really.

If the appraiser did not go inside, and the reviewer did not go inside, and the original report relied upon the photos the “client” sent to the appraiser…. Do we see a problem here that could wipe out a good portion of appraisers in the not too distant future?  Never mind that such “verification” review work will tell Wall Street that all is happy and good for much longer than the numbers should indicate.  Never mind that a photo taker, a desktop appraiser, and a desktop reviewer can all be paid for less than the fee of a single appraiser who completes their own interior inspection.

The industry needs to make noise in the national and online publications that reach “the public”.

One emerging issue is the way some ‘direct lenders’ are outpacing and directly competing with amc’s. Because they built up a department for compliant in house ordering distribution, they were able to immediately monetize that and compete directly with amc’s. They sourced other lenders and charge them to distribute and manage appraisal orders. As I mentioned previously, it’s hard to tell the difference these days. What about the not amc’s whom act function and rake just like amc’s? It’s been many years since I’ve seen a single instance of my appraisers fee aligning exactly with the consumer appraisal fee. It’s a miracle if you can land a client whom does not take a minimum of 100 dollars. They’re not amc’s see, because they are working directly with the lender in a lenders subsidiary office. They’re not amc’s because although they do everything exactly like am amc, they’re not because they are agents of the lender? Marion chime in on that one please.