Tagged: FIRREA

The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime 22

USPAP’s Typical Buyer Standard in the Fair Housing Era

The Irreconcilable Conflict Between USPAP’s Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a reference should you face a complaint grounded in disparate impact theory alone. The three-safeguard framework from Inclusive Communities provides a robust defense for any appraiser whose methodology is USPAP-compliant, well-documented, and market-supported. Introduction I want to state plainly what the appraisal profession has been tiptoeing around since roughly 2019: an appraiser cannot simultaneously comply with: 1-  USPAP’s requirement to identify and analyze the most probable (typical) buyer of a property via market data AND… 2- comply with the current iteration...

Systemic Failures in FHA Appraisal and Loan Review 30

Systemic Failures in FHA Appraisal and Loan Review

This case exposed the cracks in an FHA system where failures by the lender, the AMC, and the review process aligned in ways that no borrower could have anticipated. It shows how easily an appraisal error can escalate when every safeguard designed to prevent harm breaks down at the same time. When the first article about this case ran on July 15, 2024, it already raised serious concerns about how an FHA appraisal could miss something as basic as the type of water and sewer service. What has emerged since then paints a much larger picture, one that shows how...

Lack of Evidence, Appraiser Challenges Discrimination Claims 10

Lack of Evidence, Appraiser Challenges Discrimination Claims

The next morning I went to my trusted AI program and asked if there was any evidence of bias. “Where is the evidence?”  The issue of perceived bias and discrimination in the appraisal industry has become a highly contentious and polarizing topic in recent years, sparking intense debate and controversy. At the heart of this complex issue lies a fundamental tension between the appraisal profession’s commitment to objectivity and impartiality, and the persistent allegations of systemic racism and unfair practices that have plagued the industry. As exemplified in the response from Maryland Certified General Appraiser William Turner to an article...

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...

Is the GSEs "Appraisal Modernization" Really Just Mass Appraisal? 18

Is the GSE’s “Appraisal Modernization” Really Just Mass Appraisal?

Mass Appraisal tend to exhibit a regressive nature…  In the intricate landscape of real estate mortgage financing, the notion of appraisal waivers recently dubbed “Value Acceptance”, by the Government Sponsored Enterprises (GSEs), has stirred considerable debate. The most recent statistics show Value Acceptance accounts for up to 40% of all mortgage approvals. It is presented as part of the GSEs “Appraisal Modernization” initiative, which aims to streamline the mortgage appraisal process. However, a closer examination reveals potential drawbacks, raising questions about its efficacy and impact on the housing market. Despite its roots in a methodology designed to support appraisers, Value...

The New & Improved Fannie Mae FRAUDULATOR 2.0 42

The New & Improved Fannie Mae “FRAUDULATOR 2.0”

Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie Mae is increasingly being referred to by some, if not many American Appraisers as The Fraudulator / Underwriter 2.0 (FU-2). To be clear it is not limited to the Collateral Underwriter (CU & CU-2) software. The new Fraudulator (FU-2) combines the CU products with their numerous improper uses. The end result of which includes OUTRIGHT FRAUD being perpetrated against banks via the repurchase letters Fannie Mae now issues on a quota based system rather than because of legitimate appraisal defects....

The Scam of Racial Discrimination by Appraisers 35

The Scam of Racial Discrimination by Appraisers

More and more appraisers are retiring every day. Aside from that more and more are changing to lower liability careers. Eventually, the opportunists who have been promoting the scam of racial discrimination by appraisers such as career politicians, and ‘anti-discrimination’ software hucksters like Black Knight will be shown to be what they truly are.  Recently, a highly respected appraiser who is also a senior designated member of a well-known national professional peer association, wrote an article about a new proposed law in New York ostensibly targeting New York appraisers. Mr. Bagott’s article had an unusual amount of hyperbole within it...

The Appraisal Problem and Undue Diligence 8

The Appraisal Problem

Gone are the days of hiring a professional appraiser to solve the appraisal problem. For decades lenders have taken on the responsibility of shaping the appraisal process and dictating the solutions to the appraisal problem. Savvy appraisers push back in a positive fashion to try and enable the lender to receive a report that not only meets USPAP, FIRREA, Fannie Mae, or HUD/FHA/VA an UAD reporting guidelines, but also provides the client with a report that is clear, concise, accurate and not misleading. An appraisal report can be on time, have all the boxes checked, no inconsistencies, meet all the...

Grants to Help Train Appraisers 20

Grants to Help Train Appraisers

To establish grants directly to supervisor appraisers to help cover the training costs for each Trainee… Folks, this article appeared in American Banker on September 7, 2022. In my view, after reading it, the article appears to present a balanced perspective about what appraisers have been experiencing since the FIRREA law was mandated back in 1989. It also exposes problems with getting new people into the appraisal profession. If you have been paying attention to appraisal related activities over the years, you will recognize the names of people quoted in this American Banker article. One thing that has not been...

Racial Bias in Real Estate: Is it the Property Appraisers’ Fault? 17

Racial Bias in Real Estate: Is it the Appraisers’ Fault?

In the past year, the appraisal industry has been under attack from various academics who claim “racial bias” on the part of real property appraisers providing appraisal services to lenders who provide home mortgages. These academics do not fully understand various types of valuation specialties, the appraisers who practice in these specialties, and the myriad of laws that must be followed. Help is needed to explain the appraisal industry, including the specialties and the types of reports. An understanding of the different components of the appraisal industry is necessary to assist various academics, journalists, the media, the public, and the public...

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