Tagged: The US Department of Veterans Affairs

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...

Slow VA Appraisal Turnaround Times Is Overblown 20

Slow VA Appraisal Turnaround Times Is Overblown

Concerns about slow VA appraisal turnaround times is overblown… On September 14, 2022, US House passed HR 7735, “the Improving Access to the VA Home Loan Benefit Act of 2022“, legislation that proposes to overhaul the Department of Veterans Affairs’ appraisal requirements, including when an appraisal is required, how an appraisal is to be conducted, and who is eligible to conduct an appraisal. The Mortgage Bankers Association (MBA) has long been vocal about its support for the bill. “The bill will encourage important reforms to the agency’s requirements regarding when an appraisal is necessary, how appraisals are conducted, and who...

CFPB Investigations in Alleged Appraisal Discrimination 25

CFPB Investigations in Alleged Appraisal Discrimination

The Consumer Financial Protection Bureau (CFPB) has started investigating alleged appraisal discrimination. This is a new development, as federal investigations had so far exclusively been by HUD. The CFPB is an aggressive investigator, and AMCs, large firms and lenders should be wary. For the last year, 40% of my legal work has been occupied by issues concerning alleged discrimination – balanced between representing parties in fair housing investigations and helping clients improve compliance and decrease risk. It’s the CFPB that makes me most anxious for clients in the future. I addressed some of the details of what I’m seeing in...

Violating Appraisal Independence - Appraiser Intimidation & Coercion 12

Violating Appraisal Independence Through Harassment, Intimidation & Coercion

It shall be unlawful… to engage in any act or practice that violates appraisal independence… Appraisers, I have written the info below, which you may use if you desire to send to your clients and local real estate offices. It’s time for all appraisers to stand up to this kind of very adverse behavior, done by and promoted by many real estate brokers/agents across the US. I have been chastised multiple times by brokers, and in one instance that I know of, was excluded (by the lender who told me) from doing another assignment when I didn’t appraise a prior...

Sales Comparison Approach is Racist, as per Academics 26

Sales Comparison Approach is Racist

“…the modern appraisal industry perpetuates racial inequality through its continued use of the “sales comparison approach”… the sales comparison approach persists as the dominant method of assessing home value… the sales comparison approach — the most used method for contemporary residential appraisals — perpetuates inequities through maintaining historical hierarchies and current racialized definitions of comparability…” Appraisers, here’s a YouTube video that you MUST view. This person’s, Dr. Elizabeth Korver-Glenn, PhD, work is one of the key reasons why there is so much chatter about racist appraisers in the US. Her discussion of her book ‘Race Brokers‘ begins at the 8:30...

VA Unofficially Says NOPE to ANSI Measuring Protocol 16

VA Unofficially Says NOPE to ANSI

The other agencies, Freddie Mac, HUD/FHA, USDA, ONAP, VA have NOT (yet) adopted this ANSI measuring protocol. Appraisers, an appraiser I know sent an email to the VA asking if VA was going to require appraisers to adhere to the ANSI Z765-2021 Measuring Standard as of April 1, 2022. The appraiser received an ‘unofficial’ response back from a person within the VA connected to processing appraisals, which said: “The short answer is, no.” I say this is ‘unofficial’ because to-date, I have seen nothing “official” from VA about this topic. Only officials from within VA know whether or not they...

ASC Blaming Appraisers For Low Home Values in Communities of Color 46

ASC Blaming Appraisers

The Appraisal Subcommittee, because they were directed to do so, has produced a report, which frankly and explicitly lays the blame for low market values of homes in ‘communities of color’ directly at the feet of independent appraisers involved with mortgage lending. You will start seeing accusatory slanted media reports about this report. ABC news already has distributed it. A TV station in San Francisco has aired a story already. Yes, the report casually mentions actual facts that GOVERNMENT policies and procedures promulgated segregated and extraordinarily unfair housing issues in the US, from the 1930’s into the early 1960’s. The...

The Greatest Recession - The Hesitance to Accept Modified Appraisals 18

The Greatest Recession

The Greatest Recession is now spreading across the US. The investor’s hesitance to accept modified appraisals without interior inspections will prevent the real estate market from leading this country out of “The Greatest Recession” now spreading across the US… Appraisers provide an essential financial service according to the verbiage I’ve read from The Department of Homeland Security and various sources. We are exempt from “stay at home” orders. The State of Colorado has defined appraisal services and appraisers as providing an essential financial and professional service. Colorado says that appraisers are exempt from stay at home orders. An abundance of...

Exterior Appraisals & Temporary Appraisal Guidelines During COVID-19 16

COVID-19 Temporary Appraisal Guidelines

Fannie and Freddie are giving preference to desktop appraisals over exterior appraisals, which quite frankly, is completely backwards from what most appraisers believe to be a more reliable appraisal. HUD and the Veterans Administration, on the other hand prefer exterior appraisals…

Veterans Administration on Hybrid Appraisals - Protecting Veterans 8

Veterans Administration on Hybrid Appraisals

See the announcement by the Veterans Administration basically telling lenders and appraisal management companies we are going to protect our Veterans with sound appraisal practice. …the person providing property information to the appraiser must have entered into an agreement with the appraiser to do so. …the person who provides to the VA fee panel appraiser information must sign the appraisal report in the “Appraiser” section of the left side of the appraisal report. Assisted Appraisal Processing Program (AAPP) This section authorizes the Department of Veterans Affairs’ (VA) Secretary to issue guidance explaining the conditions under which VA permits VA fee...

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