News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...
VaCAP and 27 other State Appraisal Organizations reached out to the House Finance Services Committee concerning the upcoming Subcommittee meeting entitled “What’s Your Home Worth? A Review of the Appraisal Industry” on June 20th. The Network stresses the most qualified to testify on the appraisal profession is an appraiser. The letter also outlines some of the flaws, inconsistencies and realities of the effects of appraisal management companies and how the GSE’s current “appraisal modernization plan” is actually harmful to consumers, investors, lenders, the housing market and the economy as a whole. Fannie Mae’s own publications are being used as documentation. Hopefully the committee members ask the...
What makes a Next Generation home? Appraisers, both FNMA and FrMAC, in concert with manufactured housing builders and the Appraisal Institute, are promoting a new type of MANUFACTURED home, and CE classes to teach appraisers about them (and typical MFH). If your appraisal service area has manufactured homes, and you appraise them, you may want to peruse this essay. The name generically applied to these new manufactured homes is Next Generation (NG). Each GSE has a different name for their LENDING program, see below. Why is this happening? Up until relatively recently, the two GSE’s didn’t purchase manufactured home loans from...
Back on April 19th, I wrote about the New York AMC law in my Housing Notes newsletter. After years of AMCs chipping away at the public trust, the New York AMC law was designed to protect the consumer. The bill summary was: Relates to the registration of real estate appraisal management companies or an individual or business entity that provides appraisal management services to creditors or to secondary mortgage market participants including affiliates by the department of state. Last week, AppraisersBlogs ran it as a standalone post and I got a lot of feedback. To be clear, the bill was...
The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...
…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...
Is Smartexchange Resulting in USPAP Non-Compliance? This blog is likely going to stir up controversy. It is likely going to have a few folks calling me a loyalist to a la mode, or other similar things. Am I a loyalist? I do not see myself as such, but a la mode has been the only software that I have used in my career for residential form reporting. I do use ACI in the corporate setting as a reviewer and manager in my firm. I like and consider many of the staff at a la mode to be my friends, and I have had long relationships...
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,...
…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...
So, what are these methods and techniques? We’re told to “support” our adjustments. We hear words like “prove” your adjustments… as if there were some magic formula which can give an exact, correct, and absolutely true number. It used to be so easy… Our trainer gave us a sheet with the “right” adjustments. Simple. USPAP Standards Rule 1-1 says we must be aware of, understand, and correctly employ recognized methods and techniques. What are they? Who recognizes them? How do I apply them? So, what are these methods and techniques? Let’s look. In The Appraisal of Real Estate (ARE) p.46, it says: “Qualitative analysis techniques may also be...
