The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...
We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...
…raising de minimus shenanigans being promoted… Appraisers, a couple of weeks ago, I sent out a message about a Fee/TT quote conversation I had with an AMC clerk. I received a number of responses from appraisers across this fruited plain who said often they will receive Fee/TT quote requests for the SAME property from MULTIPLE AMC’s. That corroborates stories I hear from appraisers I talk with at conferences. The entire AMC situation is a giant time-wasting game that really doesn’t benefit the borrower at all, and least of all, appraisers. Lenders are the coaches in this game. Another message I received...
An Appraiser’s First Impressions of Clear Capital’s AVM… It’s no secret the lending industry is aggressively pursuing alternatives to traditional appraisals. While most participants in the industry will concede an appraisal is still the gold standard for collateral valuation, they increasingly see the appraisal as something to be steered around or avoided altogether. An array of products/alternatives are being bandied in lieu of a traditional appraisal: Hybrids, Evaluations, BPOs (broker price opinions), Desktop Appraisals, and outright Appraisal Waivers. The industry is also turning its attention more and more to AVMs (automated valuation models). AVMs have been around for nearly three...
…complete elimination of appraisal as part of their fully automated loan processing objectives… Our work as appraisers & appraisal issue advocates is certainly cut out for us all in 2019. I think appraisal unity is going to be needed if we are all to take on the adverse issues affecting us. That includes AI. They still have a large number of honest, & competent members. I think the rest of us will have to let AI take care of AI issues. I’m not averse to butting heads with them on specific issues when necessary but alienating them rather than seeking...
…non-appraiser inspector must not provide any significant appraisal assistance… This is Part Four in a series on Hybrid Appraisal. Be sure to read Part One, Part Two and Part Three. The term “hybrid appraisal” (as it’s currently used), means that the appraiser sits at a desk, while someone else (not an appraiser) looks at the property. It appears that the non-appraiser may or may not inspect the interior, measure the improvements – but always takes a front photo, similar to what can be found in MLS listings, or Google Earth street pictures. The basic claim is that the overall process is cheaper and faster, and...
the appraiser shall identify any person who "assists" in the appraisal process… NCREAA recently submitted a letter to the North Carolina Appraisal Board regarding hybrid / desktop appraisal products. As a result of this letter, which highlights concerns raised by NC Appraisers, NCAB is forming an ad hoc committee to clarify, define and provide guidance on these hybrid / desktop products with respect to current North Carolina Appraisal Laws. Read the letter below: The North Carolina Real Estate Appraiser Association (NCREAA) has recently received requests/inquiries from our members regarding guidance on assignments for “hybrid/interior desktop” appraisals requests they have recently...
We won’t take appraiser trainees, but we’ll take real estate trainees… That’s the million dollar question. Big banking is counting on the majority of appraisers to fall in line with whatever hybrid product they decide is best. It makes for an interesting road ahead because appraisers actually have the power to make these products a success or a failure. A hybrid appraisal is still an appraisal and must have a signature from a licensed appraiser. If banks can keep whittling away at the appraiser’s scope and can get the total appraisal fee low enough, they will achieve their goal and...
Property inspectors suing ServiceLink to obtain minimum wage… Peter Christensen wrote another article on LinkedIn about wages being paid by lenders and AMCs. This one should get your attention as it is from Independent Contractors suing an AMC. This will set a precedent and start a chain reaction. In a nut shell, property inspectors are suing ServiceLink for work performed to obtain minimum wage. Yes, you read that correctly, minimum wage. According to the article, property inspectors receive between $3 and $5 for each assignment. The article does not specify the specific service the property inspectors perform, but think bifurcated or...
Why does a hybrid appraisal work better? What are the benefits? Who benefits? Who pays? A hybrid appraisal, as it has been proposed, separates the field work from the desk work. The assumption is that an appraiser is good at filling out the forms, while another “cheaper faster” person can do the property inspection. Also, we presume that the client would be the one to select the field inspector. For this post, we also assume that the property inspector is a real estate agent. This is the third post considering “hybrid appraisal”. I had intended it to be no more...
