guidance - Appraisers Blogs

County Assessors’ Standards | AVM Final Rule Guidance

Dallas T. Kiedrowski, MNAA — Fri, 23 Aug 2024 12:30:47 +0000

County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach. The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...

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Key Part of USPAP Not Available from TAF

Dave Towne — Fri, 19 Jul 2024 12:30:37 +0000

this is a colossal failure on their part – to have a key document on BACKORDER until a month from now, or longer! Appraisers, I have a print copy of the current USPAP, but need/want a PRINT copy of the AO/FAQ Reference Manual, which TAF decided to make into a separate document for this version at a cost of $75. I prefer the printed versions, rather than the PDF so I can read it and use a highlighter for key items. I went onto the TAF web site on July 17, 2024 to order the document, and found this: In...

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Uncovering Flaws in FHA Appraisal & Loan Review Process

AppraisersBlogs — Mon, 15 Jul 2024 12:30:32 +0000

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....

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CFPB Crackdown: Unfair Practices Hurting Consumers

Guest Author — Wed, 05 Jun 2024 12:30:07 +0000

Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be particularly burdensome or concerning for borrowers. As we all know many AMCs are not paying Customary & Reasonable fee as required by TILA. They have consistently pushed down the pay of Appraisers while making undisclosed profit off consumers and prioritizing cheapest and fastest over quality and competency. The CFPB has been in communication with individuals behind the scenes and are concerned with what has been shown enough to include AMCs in their data collection process. Now is the time to...

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Low Value = Material Deficiencies? New FHA ROV Policy

Dave Towne — Fri, 03 May 2024 12:30:42 +0000

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,...

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

Dallas T. Kiedrowski, MNAA — Thu, 18 Apr 2024 12:30:24 +0000

…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...

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VA Appraisal Request Form at Heart of AIR Violation Class Action

Peter Christensen — Tue, 23 May 2023 12:30:52 +0000

While the statute doesn’t explicitly mention that providing a loan amount is an AIR violation… When a mortgage lender seeks to make a Veterans Administration-backed home loan, the lender requests an appraisal from the VA’s appraiser panel by using a form entitled Request for Determination of Reasonable Value. For many years, until it was revised in July 2022, this form had a box labelled “Refinancing-Amount of Proposed Loan.” This box asked the lender to fill in the proposed loan amount for refinances. Once submitted, the form begins the appraisal process and is provided to the appraiser assigned by the VA...

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FHA Extends Appraisal Validity Period

AppraisersBlogs — Mon, 18 Jul 2022 12:30:35 +0000

On July 12, 2022, the FHA announced that it is extending the initial appraisal validity period from 120 days to 180 days and the appraisal update validity period from 240 days to one year. This applies to case numbers assigned on or after June 1, 2022. This just seems like a bad idea at a time where many markets are seeing price declines. FHA INFO 2022-71 — July 12, 2022 In this Announcement: FHA Implements Revised Appraisal Validity Period Guidance Appraisal Logging Changes in FHA Connection See below for details. FHA Implements Revised Appraisal Validity Period Guidance Today, the Federal...

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USPAP 2020-2021 Extension

Dave Towne — Mon, 22 Feb 2021 13:30:16 +0000

2020-21 USPAP Extension – Does this mean USPAP will be on a three-year cycle going forward? USPAP has been extended for one year, effective through December, 31, 2022. This is the Appraisal Foundation news release, issued on Feb. 19, 2021: Media Contact: Amy Timmerman (202) 624-3048 amy@appraisalfoundation.org BREAKING: 2020-21 USPAP Extended for One Year (Washington, DC) February 19, 2021 – The Appraisal Foundation’s Appraisal Standards Board (ASB) announced today that the current edition of the Uniform Standards of Professional Appraisal Practice (USPAP) will be extended by one year. The 2020-2021 USPAP will now be effective until December 31, 2022. “USPAP...

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Desktop Appraisal Not the Same as Hybrids

Dave Towne — Mon, 06 Apr 2020 12:30:01 +0000

A modified desktop appraisal is NOT anything like hybrid/bifurcated reports promoted by some AMCs and lenders… Appraisers, I have a correspondence relationship with an appraiser within one of the ‘agencies’ who this past week issued new guidance for “modified” reports, including desktops. I’m not allowed to say who, or which agency, but I have actually met the person at a conference, and the individual has been in this industry about 99 years, give or take a few – no…lots! The person provided this suggestion for those of you who are beginning to do the new desktop appraisal, regardless of which...

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Temporary Appraisal Requirement Flexibilities

Dave Towne — Tue, 24 Mar 2020 12:57:15 +0000

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...

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Overwhelming Majority Are Against Hybrids

VaCAP Board — Wed, 24 Jul 2019 12:30:46 +0000

The next Virginia Real Estate Appraisal Board Meeting will be held on July 30th, 2019 @ 10:00 AM. This meeting will be a historic meeting as the board will be discussing the proposed hybrid appraisal guidance document and the corresponding 153 public comments. Also on the agenda, CoesterVMS is listed under the disciplinary cases! Why is this meeting so important? First, the 153 comments is the second highest amount of comments that have been made on any guidance document in the past year. The highest amount of comments on any proposed guidance document was by the Board of Health Professions in which 727...

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Full Transparency in Fee Disclosure

VaCAP Board — Mon, 15 Jul 2019 12:30:37 +0000

Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the appraiser by the AMC… HB 3619 has been referred to the House Financial Services Committee. VaCAP has learned over the weekend that HB 3619 has been introduced in the US House of Representatives. HB 3619, short titled “Appraisal Reform Act of 2019” amends the Financial Institutions Reform, Recovery and Enforcement Act. The main change to FIRREA deals with appraisal management company and appraiser trainee registries and the addition of a member of the Veterans Affairs on the Appraisal Subcommittee. The bill also modifies Section 2603,...

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What Will It Take?

VaCAP Board — Tue, 25 Jun 2019 12:30:14 +0000

What is it going to take for every appraiser to comment on Town Hall concerning the proposed Guidance Document on hybrid appraisals? Even if you have no intentions of ever completing a hybrid appraisal, it is important for you to place a comment on Town Hall concerning the document and these questionable products. If appraisers are not willing to step up and take a stand against actions that are contributing to the next housing crash, who will? If you have seen any of the samples floating around on the blogs and forums, you realize very quickly, these products are not credible...

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Hybrid Appraisals, Invitation to Fraud

Michael Ford — Thu, 13 Jun 2019 12:30:12 +0000

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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What is a Next Generation Home?

Dave Towne — Wed, 12 Jun 2019 12:30:57 +0000

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...

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Bifurcated Appraisals, a Controversial Topic

VaCAP Board — Thu, 06 Jun 2019 12:30:30 +0000

As most of you know, hybrid or bifurcated appraisals are a very controversial topic currently. Virginia statutes and regulations have language which gives many of us pause on the compliance of hybrid appraisals as they are being presented in the industry. The Board has published a proposed guidance document in the hopes to clarify the language in our laws. Unfortunately, the proposed guidance document falls short of providing any meaningful guidance or clarification. Per Virginia statute, the document has been published on Virginia Legislative Town Hall for public comments. At the end of the comment period, it is our understanding...

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Verisite Photo Appraisal

VaCAP Board — Tue, 19 Mar 2019 12:30:42 +0000

Appraisal Photo Report for use on loans, pick and choose pictures… Is the Welcome Mat Down and the Door Opened Wide for Fraud? “What Appraisers Need to Know about Property Data Collection” is a topic of discussion in the latest Fannie Mae Newsletter. The article describes how property data is being collected and being sent to Fannie Mae to determine the type of valuation that is needed on a property. It discusses Appraisal Modernization, Desktop appraisals, Scope of Work and USPAP. It even references The Appraisal Foundation Video on Inspections & Hybrid Appraisal Assignments. Well, Fannie Mae is the last entity that should be discussing...

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Mueller Sample Report. You Decide!

VaCAP Board — Tue, 12 Mar 2019 12:30:02 +0000

A recruiter for Mueller Services, Inc. (Mueller Reports) contacted a VaCAP member about joining their team as a W-2 employee to complete bifurcated appraisals. Our member communicated with them and received samples of their product. During the course of the communication, the recruiter mentioned, via email: In the past 30 days, we have had 23 cases in Virginia as a whole and expect that number only to increase. A quick check on the Department of Professional Occupational Regulations (DPOR) website revealed Mueller Services, Inc. is not registered as an appraisal firm. In fact they are not registered at all. In Virginia, to operate an...

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COD at The Door?

Dustin Harris — Tue, 19 Feb 2019 13:30:24 +0000

Can Appraisers Collect at the Door (COD)? In the past, it was common for appraisers to collect their fees directly from the borrower at the time of the property visit (i.e., at the door). I would take credit cards, checks, or cash while at the door. Many years ago, this was common. Now, however, that rarely happens and we usually have to wait 30- to 60-days for payment from the AMC client. So recently, when I got a COD order from HUD, I was really surprised. In fact, I thought something was bogus. I needed to check this out since...

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