Tagged: valuation

Appraisers Disappointed at Federal Banking Agencies - Appraisers Blogs 21

Appraisers Disappointed at Federal Agencies

I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. We knew that when we joined with others in signing the letter. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy...

Highly Skilled Appraisers' World. Where Would You Go to Find Comps? 3

The World of Highly Skilled Appraisers

…the world of highly skilled appraisers, who are more than just “form fillers”… I hosted a USPAP Update class on Friday January 25 (taught by an approved USPAP instructor). During the class I asked attendees if they had heard about the ‘most expensive residence sale’ in the US. Some attendees knew about this, but most didn’t. To see what I’m talking about, click on this link from Jonathan Miller’s Housing Notes blog. Scroll down and you’ll see a photo of the view from that unit, a multi-story penthouse apartment in a brand new building, I think the tallest now in New...

The Proposed Bifurcation of the Appraisal Process. Who Benefits & Why? 15

Shifting Narrative of Appraisal Modernization

…the reasoning for changing the appraisal process has shifted… Is there are Crisis? Rahm Emanuel eloquently stated “You never let a serious crisis go to waste. And what I mean by that it’s an opportunity to do things you think you could not do before.” There has been a narrative that there is a shortage of appraisers. Interestingly, this is not coming from lenders that engage appraisers directly. This is coming from Appraisal Management Companies otherwise known as “Middlemen” and the lenders that employ the Middlemen. These Middlemen will shop an appraisal assignment by blast emails to as many appraisers...

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,...

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response 109

Expert Wants to “Eliminate” Appraisers

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with an industry expert who openly stated she wants to “eliminate” the appraisal profession. No subtlety, no nuance — she wants us gone! Given the name of the website, I didn’t expect to find too many pro-appraiser viewpoints. I ran a search for the term “appraiser” on the website’s internal search engine and many of the articles that came up were about eliminating the profession or the current state of appraisal waivers.…to “eliminate” the appraisal profession…   Rather than read the article...

An Appraiser’s First Impressions of Clear Capital’s AVM 28

First Impressions of Clear Capital’s AVM

An Appraiser’s First Impressions of Clear Capital’s AVM… It’s no secret the lending industry is aggressively pursuing alternatives to traditional appraisals. While most participants in the industry will concede an appraisal is still the gold standard for collateral valuation, they increasingly see the appraisal as something to be steered around or avoided altogether. An array of products/alternatives are being bandied in lieu of a traditional appraisal: Hybrids, Evaluations, BPOs (broker price opinions), Desktop Appraisals, and outright Appraisal Waivers. The industry is also turning its attention more and more to AVMs (automated valuation models). AVMs have been around for nearly three...

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...

Comments Needed for Proposed Rule to Amend Appraisal Requirements 8

Comments Needed on Appraisal Requirement

The OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies’ regulations requiring appraisals for certain real estate-related transactions. 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 collateral that is consistent with safe and sound banking practices. The proposed rule would make conforming changes to add transactions secured by...

What is Truth or Accuracy for Appraisers? How Do We Find Accuracy? 12

What is Truth or Accuracy for Appraisers?

Are we supposed to be paid truth-seekers? The appraiser is supposed to be accurate. What is “accurate”? Dictionary meanings say accuracy is “the condition or quality of being true, correct, or exact.” Tell the truth. Can it be? Hmmm. A search for truth. OK. So how do we come to know the truth? Are we supposed to be paid truth-seekers? Cool. I read that there are four ways to “know” truth: Tradition, Authority, Insistence, and Science. Wow! Let’s look at these briefly. This sounds serious! Let’s look at USPAP and The Appraisal of Real Estate. Appraisers have long been steeped in the...

The Erosion of Bank Underwriting Standards. Let's Get Rid of Appraisers. 18

Let’s Get Rid of Appraisers. What Could Go Wrong?

Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened. It Is Now Time To Listen Again as History is About to Repeat Itself. There’s a proposal from the FDIC, Federal Reserve, and Treasury Department not to require appraisals for some mortgages under $400,000. The Trump Administration wants to disrupt the role of appraisers, but that’s not a good idea. This change can impact several groups in particular: 1) Consumers: Removing appraisers from transactions can mean a lot of loans get made that shouldn’t be made. Does that sound familiar? We...

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