Tagged: FHA

Lack of Fee Transparency: Exposing the AMC Exploitation 71

Lack of Fee Transparency: Exposing the AMC Exploitation

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge.  Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

Uncovering Flaws in FHA Appraisal & Loan Review Process 41

Uncovering Flaws in FHA Appraisal & Loan Review Process

The story of this single mother’s harrowing experience with a defective home purchase and HUD’s negligent oversight exposes deep flaws in the FHA appraisal and loan review process. After sacrificing for years to rebuild her credit and earn the right to become a homeowner, this borrower found her dream home in the country – or so she thought. During the home inspection, several issues were flagged. The seller, an investor who had purchased the home in an estate sale, was unaware of the septic system’s location. The seller agreed to have the tanks pumped so the location could be determined....

Alleged Racial Discrimination Debunked: Security Bars Removal Required by Law 15

Security Bars Removal Law Debunks Alleged Racial Discrimination

Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of “racist discrimination”… Security bars on bedroom windows is against code…  This morning I received the results of a California State Information Act Request I made regarding an alleged case of racial bias in Allendale, Oakland, California which was settled May 2024. I requested any and all documents in the case involving the appraiser because I didn’t have the complainant’s name or property address. I only had the appraiser’s name which I won’t post in text. Complainant stated appraiser told them they should...

Escaping the Black Hole: Appraisers Fleeing Mortgage Lending 27

Escaping the Black Hole: Appraisers Fleeing Mortgage Lending

Climbing out of that black hole is nearly impossible. It’s one reason why many appraisers are vacating mortgage lending appraisal assignments.  This “discrimination settlement” hit the fan last week in a news feed I get. Another appraiser (in CA) settles a discrimination complaint: Oakland homeowner settles with appraiser, lender after $300,000 lowball appraisal The entire case is based on allegations by the homeowner, who had decided the value of the home was more than the appraised amount, before the appraisal was done. But when one reads through the story, one has to question whether the appraiser truly was biased against...

Low Value = Material Deficiencies? New HUD ROV Policy 40

Low Value = Material Deficiencies? New FHA ROV Policy

The implication that if the VALUE is too low, then there must be “material deficiencies” present, is deeply troubling!  Up until recently, there has never been a standardized policy for mortgage loan related Reconsideration of Value (ROV) requests after an appraisal has been submitted. Now there is, per the attached PDF HUD/FHA mortgage letter. The GSE’s have similar policies. I’m not opposed to having a standardized ROV policy. However, these policies are in keeping with the new initiatives surrounding alleged and often unproved appraisal bias and discrimination claims. But when one reads deeper into the reason for implementing these procedures,...

The One-Mile Rule: Prudent Policy or Modern Day Redlining? 8

The One-Mile Rule: Prudent Policy or Modern Day Redlining?

…whether through redlined maps or implicit “one-mile rule,” the result can be undervalued properties in historically marginalized neighborhoods.  Throughout the history of mortgage banking and lending in the United States, underwriting policies have significantly influenced the appraisal process for home purchases and refinances. Appraisers must follow underwriter appraisal review guidelines meticulously to ensure their appraisal reports are accepted by the lender. Unfortunately, in the past, these policies became the basis for redlining, wherein certain communities were systematically denied access to mortgage credit. In this article, we delve into the historical context of underwriting policies and their influence on the appraisal...

It’s a Great Time to Leave the Appraisal Profession 189

Leaving the Appraisal Profession

It’s a Great Time to Leave the Appraisal Profession. I can hear the chorus of my fellow appraisers rising up in disagreement with me. I envision many of them screaming, “But I love being an appraiser”! Yeah, I hear you. I loved being an appraiser too. Let’s not consider what we were but what they want us to become. First, ask yourself if you are still making a livable wage. I’m not and instead of blaming myself, I started running the numbers. In, my high value market, 18% of the solds were cash sales. No appraisal required on those! Values...

The Unbiased Reality of Census Tract Data Dump... Open Letter to FHFA 11

The Unbiased Reality of Census Tract Data Dump… Open Letter to FHFA

Folks, the following letter was sent to FHFA by an appraiser I know. It was sent in response to the ‘first’ data dump FHFA made which uses CENSUS TRACT data to try to convince others that appraisers are biased by using ‘people demographics’ contained in Census Bureau info. You can find that ‘dump’ here. The writer of that first FHFA dump was identified by name, and included an email address. So the appraiser wrote a respectful email to Mr. Russell. It turns out, shortly after this FHFA document was released, Mr. Russell left FHFA. So this nice letter sent several...

Isn't that Just PAVEY! PAVE Response and Marcia Fudge 16

Isn’t that Just PAVEY! PAVE Response and Marcia Fudge

Folks, the American Enterprise Institute Housing Center has been, to date, the only major voice in the wilderness I’ve seen publicly defending appraisers and the appraisal process. They have refuted most of the highly touted ‘studies’ promoted by Dr. Andre Perry and others, which the current administration has considered the gospels of appraiser intolerable performance. The Biden-created ‘black oriented’ 13 agency PAVE Taskforce, co-chaired by HUD Secretary Marcia L. Fudge, who is a black lady, issued another report recently. AEI’s response to that is in the PDF below. Please read it. Meanwhile, Ms. Fudge recently appeared at the 75th Annual...

PAREA Program & Its Negative Impact on Diversity 17

PAREA Program & Its Negative Impact on Diversity

The study also found that the PAREA program is not as effective in providing a more accessible pathway to licensure as the traditional apprenticeship model.  Practical Applications of Real Estate Appraisal (PAREA) is a program that aims to revolutionize the real estate industry by increasing the number of appraisers. However, after listening to the Appraisal Institute speaker at yesterdays board meeting it quickly became evident that this initiative is a complete failure. You cannot start PAREA until you have received all your real estate appraisal education. 94 hours = $1,700 per McKissock Appraisal Institute speaker said that most AMC’s/banks won’t...

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