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 from your local community, state or federal regarding travel and shelter-in-place.
FHFA Directs Enterprises to Grant Flexibilities for Appraisal and Employment Verifications – News Release 3/20/20
“… Federal Housing Finance Agency (FHFA) directed Fannie Mae and Freddie Mac (the Enterprises) to provide alternative flexibilities to satisfy appraisal requirements.”
“To allow for homes to be bought, sold, and refinanced as our nation deals with the challenges of the coronavirus, the Enterprises will leverage appraisal alternatives to reduce the need for appraisers to inspect the interior of a home for eligible mortgages.”
Appraisers NOTE: Both the GSE’s are requiring an entry in the ‘Map Reference’ field on the form to show whether the report is for an “exterior” or a “desktop.” Read the instructions in the Lender Letter and Bulletin.
Also, I have included LEGAL length revised SOW, Assumptions & Limiting Conditions, etc. in PDF format below. Print those and read them! These apply to both GSE’s.
These revisions should be included in report AHEAD OF THE FIRST GSE FORM PAGE, so that readers see this before getting into the report, when doing client directed reports with the COVID-19 modifications.
FNMA (effective through May 17, 2020) – Lender Letter LL-2020-04
FREDDIE MAC Bulletin 2020-5 (effective through May 17, 2020)
Freddie’s appraisal waiver allowance is different from Fannie’s.
I recommend that you open the links above and PRINT the Lender Letter and the Bulletin in its entirety. There are instructions for the forms to be used, how they are to be used, plus required comments to be used when doing either ‘exterior-only’ or ‘desktop’ assignments using the various GSE forms.
The Lender Letter and the Bulletin provide information about the following:
- Temporary appraisal requirement flexibilities: allowing exterior-only inspection appraisals or desktop appraisals
- Desktop appraisals: allowing for purchase transactions when an interior and exterior appraisal is not available
- Exterior-only inspection appraisals: allowing for purchase and refinances of Fannie Mae-owned loans
- Revisions to the scope of work, statements of assumptions and limited conditions, and appraiser’s certifications: requiring modified language to be used with exterior-only and desktop appraisals
- Additional form instructions for appraisals: requiring identification of “exterior” or “desktop” on the interior and exterior reports
- Appraisal waivers: encouraging lenders to accept waiver offers when eligible
- Completion reports (Form 1004D): allowing alternatives when a Form 1004D cannot be obtained
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This should have been directed at appraisers and not lenders. Our safety is 100% at risk right now. This order should have also been a federal requirement for all mortgage lenders, GSE’s, etc… This shows all of us that we have 0 control of scope of work with pre-printed forms. There will be an appraiser that contracts this virus and dies from it. Sadly, even then our SOW creep issues will still most likely be over looked. Now is the time to stand against this.
I was doing my job yesterday and went into 8 houses with a mask and gloves on that I purchased to protect myself and in the last room of the inspection, the wife comes out of the shower and says “you can’t be in here, I am in quarrantine” I look at the husband who says “I forgot”. He conveniently forgot just so he could get a lower rate! Not one crap about what happened to me. At Another house the realtor tells me she will wait outside because she has to return a quick call. I go in and the house has been turned into a boarding house and two hospital workers in there were potentially exposed. I come back out and the realtor is gone. This is why we should not be going into houses. People can’t be trusted to tell us the truth or give a crap about us. I work directly for one of the largest mortgage companies in the USA and they provided no safety equipment to protect us and repeatedly patted themselves on the back for how great a job they did protecting their employees by getting everyone set up to work at home, all the while throwing us to the wolves!
you do 8 walk throughs in a day? what’s your turn time for reports look like?
Why bother with form revisions?
Residential builders are not “essential services”
Cost Approach = zero. Literally as of the effective date, the improvements can not be replaced.
Income Approach = Negative investment. No one has to pay rent and no one can be evicted.
Sales Comparison Approach = Zero. The buyer market is ordered to stay home not ordered to go look at houses to buy and move into, especially if appraisers are afraid to go into those same houses. Foreign buyers have been restricted by closed borders and reduction in airline services. Oh and moving companies? Essential for moving people in and out of homes?
Oh but, appraisers have sales less than six months old, so sure there’s a market value, so long as you correctly mark the map box on the URAR and don’t forget an HC that the market was “open and competitive” as of the effective date.
Dang and all that money spent for appraisal dictionaries and appraisal classes on “recognized methodology”.
I have not completed any reports in 12 days. My clients have not provided any direction on how they are dealing with the corona virus and the appraisers. FNMA can say all they want but it is the lenders and investors who call the shots. They have sent the employees home (work from home). But they do not care if the appraisers walk into infected properties. I have Asthma so I do not want to chance it.
FNMA does not require:
1. 1004 MC, my clients require it.
2. Photos of listings and rentals, my clients require them.
3. Cost Approach, my clients requires it.
4. Utilities to be turned on for vacant properties, my clients require it.
5. Copy of licence in every report, my clients require it.
6. Comments for comps over six months old, my clients require a comment.
7. Comments for per line adjustment over 10% of sales price, my clients require one.
As far as I can tell a 2055 drive-by is far superior to a desktop, at least the appraiser can include exterior photos of the subject and comparables (the appraisers who still drive the comps that is). I would not be surprised if FNMA will use this as additional leverage for pushing for the desktop appraisals going forward.
One of my appraiser friends has had the it’s no big deal attitude, yesterday I could tell he was coughing when I was taking to him on the phone.
Think of the news statistics you’re not seeing. All the numbers on screen but I’m like, what’s the average daily death rate anyways as if this was not going on? And right under that ‘total corona cases’ number, be it worldwide, local or whatever, shouldn’t there also be an additional stat number; ‘total people cured’? Sort of takes the steam out of the hype if one could see 300k total cases number and 299k people feeling better now number right below that, or whatever that number really is. Instead, it’s like a running stock ticker, complete with little flashing triangles and arrows, red and green. Danger Will Robinson, Danger!
Media sensationalists are having a field day. Many groups are updating, we’re safely working from home. Genius! These people really don’t relate or think about their audience when they put these messages out. Everyone is essential. These people need to get back to work soon and my kids need to go back to school. We’ve had enough. By the time they iron out these ‘solutions’ the event will be over. They’ve turned this into another corporate give away.
They don’t care about your safety, they only care about profits……if this continues for a few months the economy will totally collapse and it will be worse than the Great Depression, there will be nothing left for people to go back to work for cause there will essentially will be no businesses to go back to
I had 5 today and 4 tomorrow. Gloves, masks and don’t touch anything. I look at is as doing my part to keep the economy going. Stay safe out there.
Temporary? Now that the can has been opened you can pretty much assume exterior only and desktops are going to be the norm.
So just to add to the group…4 inspections, I do not have any masks ( can’t find any) but gloves. Tell all occupants to open all doors to the rooms and turn on lights. I explain the gloves to all…..1st house the homeowner says ” oh we don’t care about that, we aren’t paying any attention to it”…..as she goes coughing down the hallway. Out of 4 homes only 1 homeowner were able to execute the open the doors to all rooms and turn on the lights. So, how do we expect this virus not to travel with this kind of intelligence? Yesterday I started asking for my assignments to be turned into drive bys’……crickets.
One of my clients just got back to me. If they order the appraisal as a 1004 (URAR), all I need to do is request a drive-by report (because I will not go into the property) and they will accept it. It appears they will let the appraisers make the call. Good for them. They do want exterior photos of the subject and the comparables and will pay $500 for a 2055 vs $650 for the 1004. If a 2055 will not work I can just decline the request no questions asked. One of my other clients never got back to me, it might be because everyone is working from home. I do not trust the property owners, remember some of them are the same people who do not even flush the toilet when they know the appraiser is taking photos.
Yeah, but that’s the reality of it if you’re not in a vulnerable group. You don’t need to worry. Just don’t spread it to your parents. Or if you’re in the vulnerable group category, you should not be there. This will all blow over in a few months. But the special interest giveaways and new allowances are likely to remain firmly entrenched. Be careful what you wish for.
It looks like the VA is not changing anything, they just told the appraisers to ask questions, cover your face and wash your hands. Thanks VA, that was really helpful, NOT. Any word from FHA yet?
With all the BS Regulatory CRAP we have had to endure the past 12 years …… the Mortgage Market STILL collapsed and had to be bailed out AGAIN by the FED.
Mnuchin now handing purchased Mortgage Bonds to Blackrock to manage??? ……PURE INSANITY.
Watch the video. Mortgage Servicers have no money to pay their investors. So they also have no money to pay you.
The series of amc letters reminding us they’re part of the essential services circle is also entertaining. Good thing lenders don’t need to use them in the first place. Amc’s are like the annoying friend of a friend whom somehow always shows up to the party but is never directly invited. Please don’t forget out me!
Lower housing pricing is a good thing for some people. When are they going to learn, debt is dangerous and your home is not an atm machine. Nobody whom called this feels good about it but the message was always there. Liberty Report with Ron Paul. They knew this was coming years ago. It was not if, but when.
Origination is poised to take a nose dive. Hopefully appraisers will have learned their lesson about competing by fee, but that’s doubtful. I’m not so sure about special allowances. Full service 1004’s is all I know, probably just stick with that.
Too soon to repost the circa 2010 empty paper bag meme with the caption; ‘Actual photo of a mortgage backed security’? Save that for a zinger later. It’s just another day of news to me.
The bright side of government mismanagement?
The whole country, panicking for what?
Thank god we have sensationalist media to carry us through’.
CDC’s only job is to properly identify, then prevent the spread of infectious disease. They failed miserably. Wreckless government agency incompetency.
Open everything up and tell the old and sick people to just close their doors. None of us need armchair health guidance from the federal government or lenders or unnecessary middle amc managers, or any of these people. The last place we turn to for meaningful information about our health is the government. Nobody needs to suddenly shift ideologies and start discriminating against people based on their occupations either. You can keep your job, you can’t. You work from home, you scoot to welfare. You here is your permission slip to have temporary liberty for the day. How long can they keep selling this and why are people buying it?
Live free or die.
Read that on a flag someplace, once.
But if the virus dies in the summer. It’s a good thing we got global warming. At least the hockey stick math works for the number of infected.
But I don’t want my elderly relatives to die this way. I don’t want my elderly friends to die this way. I don’t even want the homeless people to die this way, with their last contribution to society being a giant unpaid hospital bill. Now, with younger people dying, it’s time to consider many things. The meaning of life? The meaning of death? The meaning of power and control? The meaning of empathy and charity?
Lots to think about under the new world order. Wash your hands and stay home. The market is gonna crash, people are going to be underwater in mortgages that you told them their “value” represented an “open and competitive market” that existed as of the day, with so many lockdowns and stay at home orders all over the country, heck all over the world. And of course foreign buyers were never a portion of your market, so their current non-existence has no need of being addressed under “market conditions” Close your eyes, you don’t know. Someone provided boiler plate as an “acceptable” “out”, instead of allowing a back dating of the effective date, by two weeks. Oh no, a little retro would be too risky on the edge of a giant cliff.