Tagged: FNMA

Ending the Conservatorship... Potential Changes to GSEs Gaining Steam 2

Potential Changes to GSEs Gaining Steam

Folks, if you have not been hiding under a rock since 2009, you know that both FNMA and FrMAC have been under ‘conservatorship’, regulated by FHFA for over the past 10+ years. If you’ve been paying attention, you also know that over the past few years there has been increasing talk to end the conservatorship, and now, to add competitors to the GSE’s in the mortgage loan purchase arena. That prospect is outlined in the latest Report to Congress by Mark Calabria, Director of FHFA, summarized in this article posted Tues, June 16, 2020, in Mortgage News Daily: The Federal...

Professional Opinions Can Never Be Replaced By Automation 10

Professional Opinions Can Never Be Replaced

Professional OPINIONS have value that can never, repeat NEVER be replaced by automation… Earlier this week, George Dell‘s article titled “Why is Residential Appraisal in Trouble?” was published on AppraisersBlogs. Respectfully, George misses or misinterprets a few items. There has been zero evidence that an AVM produces credible approximations of MARKET VALUE consistently or with even an acceptable degree of variance. None. Like George indicates, an AVM is NOT an appraisal. By definition, it is not an appraisal. FIRREA required appraisal standards; NOT banking industry and TAF proposed alternatives. TAF is very far out of line giving AVMs any imprimatur...

Temporary Appraisal Requirement Flexibilities - FHFA Allowing Alternatives 18

Temporary Appraisal Requirement Flexibilities

Temporary Guidance From Fannie Mae… FNMA has issued temporary guidance on appraisal requirements, including allowing desktop & exterior-only appraisals… Folks, due to the ongoing COVID-19 national emergency, the GSE regulator FHFA and both GSE’s have issued new (temporary) guidance on Monday, March 23, 2020. These remain in effect through May 17, 2020, but could be extended due to the on-going situation. NOTE: I have seen nothing yet from FHA or VA. Appraisers (and AMCs) CANNOT modify assignments or reports without specific authorization from the lender client. Appraisers CAN choose to do, or not do, assignments under the inspection guidelines, and per directives...

Is That an Arm’s-Length Transaction? The Necessary Analysis 14

Is That an Arm’s-Length Transaction?

USPAP does not define the term arm’s-length transaction. Fannie Mae also lacks such a definition. Yet, both of them call for the appraiser to use only arm’s-length transactions as comparable sales… How often do we appraisers get into the mode where we think we know it all? Occasionally, do we need to step back and look at the way we do things, just to make sure we are not missing something? Is what we know to be true and correct really true and correct? I raise this issue relative to the concept of what an arm’s-length transaction is. Are we...

Incorrect Comments in Multi-Family Appraisal Report 35

Incorrect Comments in Multi-Family Report

I have in my possession an appraisal for a DUPLEX (2 family residence) on a FNMA 1025/FrMac 72 form, commonly called the ‘1025 Form’ which was done by a Certified Residential Appraiser licensed for 8 yrs, 6 months. Items “observed” in the report: UAD rating numbers are used for Quality and Condition. 1025 forms are not UAD coded, so why are these used? Please don’t tell me “the client said so” because the client is incorrect, and may not be aware. Use the standard wording for those items, and provide a definition description of the standard wording you use. The Highest and...

Data and Verification Sources Are Critical 11

Data and Verification Sources Are Critical

The genesis for this essay began when I heard from another appraiser that a VA report reviewer rejected the comparables “DOC Number” on the Verification Source(s) line. The reviewer said the “DOC Number” was not acceptable as a Verification Source. In fact, VA has said in a newsletter to appraisers that “… Assessor’s File Number may never be used as a Verification Source.” I disagree with that position, and this essay explains why. It also explains what appraisers should do to provide credible Data and Verification Source(s) in reports. Caveat: I don’t do VA assignments. I decided that a deeper dive...

Time Saving Shortcuts Undermines Our Profession. Skip the Comp Photos 53

Skipping Comp Photos, Suicidal Shortcuts

I refuse to undermine my own profession by pretending that time saving shortcuts are always acceptable just because they are ‘more modern and progressive’. I know how long it takes to produce USPAP compliant, credible appraisal results. I charge accordingly for my time. I make no effort to compete on fees with half assed hybrids, evaluations, or single approach partially performed field work. Respectfully, neither should anyone else. Please stop undermining our own profession…. Recently The Appraiser Coach posted an article and links to a podcast suggesting its no longer necessary to photograph our comparable sales. I wrote a counter...

Failure to Inspect & Photograph Comps Backfires on Appraisers 52

Appraisers, did you Shoot yourself in the Foot?

When I explain the rules many of the appraisers start complaining: “An MLS photograph depicts the house at the time it sold so it’s more accurate than my photograph would be”… There’s a lot of yelling and screaming about bifurcated appraisals. Unfortunately, appraisers may have shot themselves in the foot when it comes to this issue. Allow me to provide an analogy to help explain the issue. I’m not sure if this happens in other areas of the country but in Seattle there is a strange “left leaning” way they do things: State and Federal governments perform numerous traffic studies, to...

Price Fixing & Discrimination - FNMA & FHLMC Bond Price Fixing Claims 7

FNMA & FHLMC Bond Price Fixing Claims

Are the profits being reported by Fannie and Freddie being skewed because of price fixing? In an article released on CNBC by Reuters, US District Judge Jed Rakoff ruled investors can pursue antitrust claims against banks for conspiring to fix prices of bonds from Fannie Mae and Freddie Mac. According to the article, there are transcripts of chat room discussions that prove a conspiracy to price fix mortgage backed bonds from Fannie and Freddie between January 2009 and January 2016. Rakoff wrote. The chats unmistakably show traders, acting on behalf of those defendants, agreeing to fix prices at a specific level before...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. https://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

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