Tagged: NAR

Should We Real Estate Appraisers Stop Making Adjustments? 43

Should Adjustments Actually Be Done?

How much credit should we give ourselves when it comes to making adjustments? Making adjustments is controversial. USPAP says nothing about adjustments – it does not require us to make them. They are a GSE construct. So, should we real estate appraisers stop making adjustments? Clients pay us for opinions of value, so our adjustments are really opinions based on what the market tells us (or that’s what we should base them on), but they are still opinions we form; they are not facts we find. So, maybe, should we stop making adjustments? We derive our adjustments from sources such...

Feds Deny Public Hearing - Denial of a Public Hearing is Undemocratic 16

Feds Deny Public Hearing

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...

COD at The Door? - Can Appraisers Collect at the Door? 28

COD at The Door?

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...

Appraisals Costs Hardly a Burdensome Cost? Appraisers & Realtors Unite! 19

Standing With Us Protecting Consumers!

…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...

Increased Regulatory Persecution of Real Estate Appraisers - USPAP 21

Increased Regulatory Persecution of Appraisers

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,...

USPAP Confidentiality Questions... Can Using a Contractor Be a Violation? 7

USPAP & Questions on Confidentiality

How can using such a contractor not be a violation? In the context of a real estate appraisal, especially a residential real estate appraisal for a lender thru an AMC, what is confidential? First, look at USPAP’s definition of confidential information (lines 105 – 108 in the 2018-2019 edition). It says “confidential information [is] information that is either…identified by the client as confidential when providing it to an appraiser and that is not available from any other source; or…classified as confidential or private by applicable law or regulation” (ibid; emphasis added). Notice confidentiality flows to the client, not to any...

What Are You Waiting For? Only 179 Comments...Please Comment Now! 13

What Are You Waiting For?

Please comment now! VaCAP sent out a “Call to Action” a month ago to comment on the proposed increase in the appraisal threshold to $400,000. As of this writing, only 179 comments have been received. This is our future, please comment now! Comments must be received by February 5, 2019. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property...

Embarrassing Indeed! Inspections Can Sometimes Be Embarrassing... 9

Inspections Can Sometimes Be Embarrassing

Inspections can occasionally get embarrassing, right? It happens to all of us. That’s just part of the appraisal business. But that does not make things any easier or less embarrassing, does it. Let me tell you three stories. First is the house with the unique basement. It’s your typical single-family residence on the ground floor; nothing out of the ordinary, nothing embarrassing. Then I tell the owner I need to go into the basement to inspect it. He hesitantly says OK, so into the basement we go. It was not your typical basement. It looked like some kind of department...

Closed for Business, Sorry Folks! Appraisal Management Company Fiasco 62

Closed for Business, Sorry Folks!

For those who are not familiar with what an AMC is, it is short for Appraisal Management Company. They are not new, but since the adoption of the Home Valuation Code of Conduct, the number and the frequency of their use have increased. They are the order manager for the lender and ensure appraiser independence. If you have not already read “What’s Not in Your Wallet” or “Round and Round!”, go get a little more familiar before reading this. AMCs manage appraisal orders. They find the appraisers to give the orders to, and are supposed to provide quality control reviews...

What Are Recognized Techniques & Methods? Adjustments: Now What? 14

Adjustments: Now What?

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...

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