Unresolved Complaints Filed with HUD
The lack of resolution in the fair housing complaints filed with HUD regarding alleged appraisal discrimination has become a pressing concern for all parties involved. As highlighted by Peter Christensen, HUD has received over 200 such complaints since 2020, yet has failed to make a determination on the merits of any of them, either way. This suggests that the complaints are not as straightforward as they may initially appear, and that there are significant challenges in distinguishing legitimate grievances from those driven by other factors.
As Dave Towne’s insightful comment on Peter’s LinkedIn post points out, the fact that HUD has been unable to find sufficient grounds to pursue these discrimination claims is telling. It suggests that the bar for proving appraisal discrimination is exceptionally high, as the complaints filed thus far have seemingly revolved more around disputes over the property’s value than clear evidence of bias or unfair treatment. This underscores the challenges inherent in distinguishing between legitimate grievances and those driven by borrowers’ own financial motives or dissatisfaction with the appraisal process.
Overall, the facts presented suggest that the “unresolved complaints” may not be as clear-cut cases of discrimination as they are being portrayed. The challenges in proving appraisal discrimination, as well as the potential for some complaints to be driven by borrowers’ own financial motives, should be considered when evaluating these complaints.
Peter Christensen’s LinkedIn post:
Unresolved complaints filed with HUD alleging Fair Housing Act violations about appraisals have become a serious problem – the lack of resolution is a concern for the parties involved (on all sides), fair housing advocates and defense counsel. HUD has received 200+ complaints regarding appraisals since 2020, but has not determined any on the merits, either way. This is as much of a problem for the consumers submitting complaints to HUD, as it is for the appraisers, AMCs and lenders responding to them.
HUD’s inaction is also leading consumers to file complaints with alternative agencies. And, it’s now leading some consumers to abandon years-old HUD complaints and file court cases without waiting for HUD. The most recent court case alleging appraisal discrimination makes this point.
In this new case, a retired NFL player and his wife have filed fair housing discrimination legal claims. The claims involve multiple appraisals/appraisal reviews for the purpose of a proposed reverse mortgage. There are 9 appraisals/reviews performed by different appraisers from November 2020 to August 2021 identified in the case. The value opinions of the suburban home range from $1.5m to $3.15m.* The borrowers allege that the low values in that range, which prevented their reverse mortgage, stem from bias based on their race and on the predominant race in their neighborhood. As reflected in the snippet below from their court complaint, they filed a HUD complaint in January 2022 and waited for a result for more than 2 years – until finally withdrawing the HUD complaint in April 2024 to pursue a civil action in state court.
In other matters, I’ve seen appraisers so frustrated with HUD’s inaction, that the appraisers themselves have contemplated heading to court to somehow force HUD to make a determination. These appraisers know that they themselves have not engaged in illegal discrimination and simply want to be cleared.
* For the curious, here are the values/dates of value in the 9 different appraisers’ reports:
- 11/18/20: $3.1m
- 1/13/21 (4 reports with same date of value): $3.1m, $2.6, $2.5m, $1.5m
- 1/26/21: $2.5m
- 6/3/21: $3.15m
- 6/20/21: $3.1m
- 8/20/21: $3.1m
- Uncovering Flaws in FHA Appraisal & Loan Review Process - July 15, 2024
- Exposing Predatory AMCs - June 14, 2024
- Unresolved Complaints Filed with HUD - May 28, 2024
It’s so very odd that if they can not prove the appraiser had bias, or just sucked at their job, why can’t the cases be moved forward with discipline as needed due to poor work product, or dropped all together.
I am caught up a HUD compliant and it has now been 18 months and still going. The VA cleared first when that homeowner filed a complaint with them, they found no bias so the homeowner went over to HUD. The investigator has now charged me with harassment can coercion since I contacted the homeowner to settle this after the HUD investigator wrote a email to me stating that I could contact the homeowner, entrapment is my mind. HUD has screwed up this case which should never have been ok’d since the VA already cleared me. This homeowner has dragged me though the mud since the appraisal was done on 11/09/2021. A class action lawsuit should be started against HUD for this obvious abuse of the system!
It’s also a crime to knowingly file a false report to the government. Sadly they never enforce it.
Unless there are damages for doing so, they never will.
Having been a senior appraiser at the VA, I can tell you first hand they take these matters very, very seriously. A highly qualified staff senior appraiser is assigned the case and leaves no stone unturned. It is a thorough and unbiased review of all aspects of the appraisal. If VA found no bias or racism you can be assured there is no bias or racism. HUD is embarrassing themselves by calling into question the integrity of the VA let alone the appraiser. They should have done the right thing and deferred to the VA findings. Just goes to show there is a conspiracy taking place at the highest levels.
As Ken has shared more of the detailed background with me I can confirm there is neither an iota of bias apparent in the work in question, nor any significant defect in the appraisal itself.
The FACT that the United States Veterans Administration has investigated the complaint and cleared him is indicative and telling.
HUDs normal process in every one of these cases is to ask or suggest appraisers may want to settle the cases based on no more than their initial notification statement. Essentially they look for coerced settlements, so they can go back to Maxine Waters and say “Gee, you are right! There WAS bias afterall…as evidenced by the appraiser refunding the fees in settlement.”
Under former HUD Secretary Marcia Fudge, anti appraiser bias and pro “People of Color” bias was evident in their daily operations. This can be seen in carefully reading former Secretary Fudge’s “Strategic Plan” in which she specifically states a benefit being sought would be beneficially “particularly for People of Color”.
Try using THAT phrase in a real estate appraisal and see what happens!
People in government need to understand that the oft cited Brookings Institute Study is neither objective, nor capable of withstanding scrutiny. It’s author, Dr. Andre Perry himself seems very biased based upon reading his own book.
The learned doctor is to be admired for his life’s achievements in spite of the obstacles, however his experiences had left him with an undeniable prejudice agaisnt White People. Read his book. Particularly the story of how he originally lived with his Aunt in her old, run down house and then later how it was lost in a tax lien sale because of ‘systemic racism’ (as opposed to being run down and unable to be sold or refinanced to avoid the lien sale).
MANY of the complainants today are either “.edu” social justice educators or advocates, or actual friends of Dr. Perry. No wonder there are so many unsupported and spurious claims!.
Award Winning Activist Reporter Julian Glover who has hyped several dubious (false) bias claims is another source of the claimed bias flames being fanned.
Organizations such as AI should have been in the forefront of investigating and refuting the bias claims. Sadly they saw other opportunity associated with the bias claim frenzy.
Only recently has their new President, CIndy Chance indicated a desire to start looking into the issues disproportionately affecting residential appraisers for GSE FRTs.
Our very own State Appraiser Investigator with our State Real Estate Commission said how can he ever prove that the Appraiser applied some sort of BIAS? I said BINGO!
SO TO ALL WHO WANT TO CRY BIAS/RACISM….. PROVE IT!
That isn’t the point of it all. Someone is trying to force a narrative to be true that isn’t true. Think about all that has happened in the past 4 years. COVID Deaths have been misconstrued to fit a narrative. The Vaccination safety as been misconstrued to fit a narrative; BLM was misconstrued; Climate change narrative has greatly changed in the past 40 years – this is nothing more than what all those have been, a cash grab by someone that far richer than we are to get more than they already have.
BINGO!!!
There is very big money in being a non profit advocacy group where mitigation funds can be coerced from large railways ( http://www.mfford.blogspot.com CFASE), or developers; or professions where E&O insurance is common.
Fighting homelessness? No problem. Have a hundred million per year and do nothing! Fighting drugs? Gangs? Seeking “Affordable Housing”? Same thing. Set up a non profit. Get big grants. Donate to your favorite Act Blue recipient, and you too can become wealthy.
Appraisers should form our own independent non profit enterprise, to better educate the American public? Tap into some of this grant money to create additional employment positions. On the importance of independent checks and balances, the real value of the appraisers participation in the lending process to protect consumers, smart strategies for citizen engagement with lenders, etc. The issues are framed differently with alternative narratives. However the issues remain essentially the same; The appraisal communities dedicated motivation to protect American consumers. This is the primary reason appraisers have been required in the lending process this entire time, a safeguard against debt traps. This is supposed to be what so much lending regulation was created for in the first place. Back to the basics.
A FEW POINTS:
1. All the whitewashing stories I seen are all refinances. How would the appraiser even know what value on his/her appraisal report would negatively affect the borrowers ?
2. The NFL borrower says the 1.5 million appraiser is racist. So my question is, what if that $1.5 million appraiser was the same color as the NFL borrower. What would the NFLer’s explanation be then for receiving a $1.5 appraisal?
3. Why haven’t we seen 1 single appraiser’s license be suspended or revoked for racial bias ?
4. When the “whitewashing” experiment is performed there are more than 1 variable being changed (2 different appraisers & 2 different homeowners assumed race). you didn’t need to pay attention in 9th grade Science class to understand you can only change 1 variable when performing an experiment, you just need common sense.
I asked perplexity ai , a free ai search engine: are there final cases of discrimination against appraisers?
and received the following answer:
Based on the search results provided, there do not appear to be any final court cases or rulings specifically against appraisers for racial discrimination in home appraisals. The most significant pending case discussed is against Wells Fargo bank, not individual appraisers.
Here are the key points from the search results:
– The case “In re Wells Fargo Mortgage Discrimination Litigation” alleges Wells Fargo discriminated against Black and Hispanic borrowers in mortgage lending, including through appraisals. However, it does not name any appraisers or appraisal companies as defendants.[1]
– One case that did involve an appraiser as a defendant, Tate-Austin v. Miller, was settled out of court. The appraiser agreed to discrimination training and other terms, but there was no final court ruling on the merits of the discrimination claims against her.[2][4]
– The search results discuss examples of homeowners who believe they experienced discrimination through appraisals, such as the Horton family in Florida and the Austin family in California. However, these appear to be individual incidents rather than concluded court cases against appraisers.[2][3]
– The Department of Justice blog post mentions they are working with the CFPB to combat discrimination in appraisals, but does not cite any specific finalized legal cases against appraisers at this point.[5]
So in summary, while there are pending lawsuits and allegations of racial discrimination occurring through the home appraisal process, the search results do not provide evidence of any final court rulings or cases where appraisers were found legally liable for discrimination. The most prominent case targets a lender’s practices rather than individual appraisers.[1][2][3][4][5]
Citations:
[1] https://www.valuationlegal.com/2023/08/the-most-significant-appraisal-discrimination-case-doesnt-name-an-appraiser-as-a-defendant/
[2] https://www.fairhousingnorcal.org/press-releases-and-statements/discrimination-lawsuit-alleging-race-discrimination-in-home-appraisal-process-settled-with-appraiser
[3] https://www.nytimes.com/2020/08/25/realestate/blacks-minorities-appraisals-discrimination.html
[4] https://www.nar.realtor/legal-case-summaries/homeowners-enter-settlement-agreement-with-appraiser-in-racial-bias-suit
[5] https://www.justice.gov/opa/blog/protecting-homeowners-discriminatory-home-appraisals
what I like about the perplexity ai program is that it provides the citations for all of its information.
Funny how AI passes over the Abeena Horton Florida case so easily.
1. Former Staff attorney for Black Knight
2. Never did file any follow up after the initial publicity push
3. Black Knight was on verge of announcing new AVM software which among other things ‘would’ eliminate bias in appraising (though still based on demographic weighting which is the verry definition of bias).
4. Black Knight is among the first of 6 vendors selected, for the GSEs Value Acceptance fraud facilitation program.
The Tate-Austin v Miller case was settled by the E&O providers…NOT because Mrs Miller did anything wrong. Deaths of family members during the case put an additional huge burden on her to settle. Mary Cummings has a lot of background on this particular case.
I have been through this descimation process for over 3 1/2 years now with two goverment agencies so if there is anyone who knows the in’s and out’s of this witch hunt please feel free to contact me and I can give you some advice if you need it. Until this happens to you you have no idea how this will effect you mind-set, business and overall health, it is horrible.
I can only imagine and I’m sorry that you are going through this. I wish I had advise for. I have attempted to sue the borrower for lost work, defamation, lost time, emotional damage and you attempt to salvage your career? I would think about a counters suite starting with what you earned in the 5 years prior to this case starting and move forward with that number multiplied by however many years to needed/wanted to remain in business, say 20 years. So if you were earning 100K, multiply that by the 20 and you get 2 Mill. Through on additional funds to recoup your lost time, etc and start with 2.5-3 million. Maybe he will recant from his baseless claims with said suit. Maybe he won’t, but just a thought.
Sounds like incompetence more than racism. 1.5 to 3.15 within 2 months. Yea, somebody is wrong but that doesn’t equate into racism. That’s just the low road hoping to intimidate. Sad to say. Wow lot of appraisals. Seems like they are trying to find the highest one. Now that appraiser will certainly be unbiased, lol.
Paul, there is not a single law firm out there that will even look at this case, I have tried. Not even the ACLU and those types of organizations. No one wants to be affiliated with racism with a black homeowner and white appraiser. It would be bad for business, you are on your own. This best thing I found out is to file a complaint with the HUD Inspector General’s Office for waste and abuse. I have a case going now with them and that outcome should be forthcoming in 3 or 4 months. I am trying to start a class action law suit against HUD, if you know anyone or a law firm that would take this case to protect our industry let me know. We as appraisers need to start fighting against HUD. Read the HUD profile on this that started this whole mess and you will be scared to death. Look up on Google PAVE and you will get the PDF copy, all appraisers need to read this, very eye opening!!!!!!
Can you not represent yourself? I totally understand that is not advisable, but considering you are the appraisal expert in the court room, not the borrower or their attorney.
Ken, contact Shane Lanham and ask if his legal team can recommend a lawyer to represent you in your defamation case, since they are currently handling Shane’s own defamation matter.
https://www.buzzfile.com/business/20.s.20-Valuations-LLC-410-665-2359
If you’re considering a class action lawsuit, you may want to reach out to Janette Miller, Kimberly DeFilippis, and others who have been involved in similar cases. There have been numerous high-profile cases alleging discrimination by appraisers. A lawyer may be able to help you obtain a list of appraisers who have had complaints filed against them for alleged discriminatory practices. You need to locate the appraisers in the 200+ cases that Peter referenced.
Other important evidence gathering would include the FHFA’s monthly progress reports regarding conservatorship of the GSE’s. Alongside their stated guidance demands which the progress reports are based upon. FHFA requires GSE’s to submit more appraisal service complaints, and conditions executives compensation packages on their continued reporting of appraisers and removal or diminishment of appraisers from the standard lending process.
Talk about entitlement. They can afford nine appraisals all at once on a mansion. That is not ‘a suburban home’.
Fighting HUD by yourself would be death, or trying to get at the homeowner through the legal process would be the same. The Inspector General’s Office at HUD took my complaint. The investigator did not follow the HUD guideline that guide this case so I am going to the OIG’s office. They should find me not guilty. I am drafting a civil rights claim against them for not following there own guidelines with the help of AI. I might be able to get a claim paid by them so this does not go to court which I am sure they would not like, and then think of the publicity if this gets out in the public so I think they might pay me to go away. They have ruined by career and health. I am still working through this. Thanks for you support. Ken
I was talking about suing the borrower directly, not HUD. They have way to much money and could file injunction after injunction.
I’ve always believed from the beginnings of this witch hunt if appraisers are racist then so too are realtors, assessors and valuation companies as there is a direct correlation to one another. They can’t have it both ways. Also, you typically find these complaints with refinances and not sales for the obvious reason of self-serving greed. It’s just another way of manipulating the system.
TLD- thanks. The VA actually had a review appraiser look at this appraisal and I did make a few minor mistake but it was no based on race. I appraised the home not the homeowner. HUD hired a outside contractor to do the review and she had no idea what she was doing or looking at, I had to hold her hand through the entire appraisal. For instance I just stated “Contributory Value” and she said, “What is that”. My hope is that the Inspector General’s Office fires her and settles with me. Read the PAVE handbook put out by HUD and you can see that they are after the appraisal profession, it should scare the heck out of anyone in the profession. When this is over I will let everyone know. The VA investigation should have been the end of this lost search but no, only HUD and investigate what has already been investigated and do it completely against their own guidelines. Thanks.
Appraisers are gone from the lending industry. They are dead and dont know it yet. This has been a slow, methodical planned process and not by chance. We are perceived as the last stumbling block to allowing big business full, unbridled reign of the banking industry. All it took was getting all their ducks in a row with the cudegra being racism. We are now evil in the eyes of the public and our politicians. In other words, ” the kiss of death”. And, conveniently AI comes to the rescue with its new and improved lack of racism. Coincidence? I may be cynical but we all just need to redirect our expertise to other appraisal opportunities because no matter how hard we yell and stomp our feet it is wasted effort. We have no power and no one to take up the cause of a bunch of racists. Hell, we don’t even support our own brother and sister appraisers. This is the reality pure and simple. It’s a done deal folks. Turn out the lights on your way out.
True.
We are still viable in litigation work, estate planning, divorce appraisals, easements, pre listings, partitions and a host of private work including purchase appraisals where interested parties procure waivers and buyers want to know if they are paying MV or not; but MISMO stated a goal of eliminating us over 10 years ago. (Read all about here in AB).
Time to get out of FRT-lender work completely.
What about the every day American consumer of mortgage lending services? I’ve actually turned down such requests. Who would stand in direct opposition as a 1099 without being able to afford representation, and insurers whom settle regardless of merit of claim, against international lending corporations to directly challenge them on behalf of a complete stranger, accept all the risk? Appraisal modernization, the appraisal waiver program, is not functional.
TLD- you are absolutely correct. The mortgage meltdown was the start and now this. They do not want us in the loop you kill one deal (supposedly) and you are the monster. I saw this coming all the way. There will be another financial crisis and it is coming soon with no appraisers to stop this from coming. I have been through two not one but two racial investigation from the government. The process is the punishment, almost 3 years now of investigations. I am trying start a “Class Action” lawsuit against HUD to stop this racist purge in the industry. Anybody out there know of a law firm to take this case? Give me a number and let’s up protect this industry that is under attack!!!
Not to be a pessimist but I’m afraid that will probably never happen. A lawsuit suit of that magnitude is a losing proposition for any lawyer. While it makes a good story line for Hollywood, in reality it’s a loser. Firstly, it’s the US government who has unlimited resources and would drive any law firm into bankruptcy. Secondly, if you could find anyone it would require a cohesive group that we certainly are not. We have those among us who would sell their mother off for $25. The only practical approach, that is also unlikely, is to find politicians willing to take up the cause but clear as the nose on my face, that is highly unlikely as we have been labeled racist by many of the politicians including the president and the media. This is my point. They’ve covered all the bases. This was a chess game from the get-go and after trial and error they figured it out.They are miles ahead of us and there is no catching up short of a miracle and I don’t see that on the menu.
Ken, you should reach out to Shane.
March 9, 2021, 2:41 pm By Tim Glaze
The Department of Housing and Urban Development (HUD) has announced that JPMorgan Chase has come to an agreement with a Black homeowner who claimed the bank’s mortgage division – relying on a valuation done by an appraiser – valued her home at an amount lower than its actual worth because of her race.
Under the conciliation agreement, JPMorgan will pay the homeowner, a Black woman, $50,000. The finance giant will also begin training home lending advisors and client care specialists in the reconsideration of value process and fair lending issues related to appraisals.
“Discrimination in home buying, mortgage lending and property appraisal deprives qualified individuals of an equal opportunity to pursue homeownership as a path to family stability and financial security,” Jeanine Worden, HUD’s acting assistant secretary for Fair Housing and Equal Opportunity, said in a statement. “HUD is committed to ensuring that all housing, whether for rent or for sale, is free from discrimination.”
JPMorgan quickly denied any wrongdoing or racial bias upon the homeowner filing a complaint in October 2020. In a statement, the company said it is “firmly committed to the principles of home ownership, fair housing, and equal opportunity.”
A spokesperson for JPMorgan said in a written statement that the bank researched the matter extensively. “Appraisers are independent contractors who are not employed by the bank,” the spokesperson said. “They are specialists in the specific regions and use market-based comparisons to come up with a value. Our internal review of the appraisal assessment, as well as a market analysis, found no substantive issues and supported the appraiser’s value.”
___________________
___________________
According to official court documents, JPMorgan entered into the agreement “solely for the purpose of obtaining expeditious administrative closure of this matter.”
Though the bank did not admit to any wrongdoing or any appraisal bias, it moved quickly to update its policies on valuations.
Specifically, employees will be trained on how to handle complaints of discrimination in the appraisal process, as well as handling the process for customers who wish to submit a Reconsideration of Value (ROV) request. Appraisers must also provide three comparable sales on each listing.
Additionally, JPMorgan will include a cover letter with language pertaining to valuation bias on all appraisal reports it sends to its customers. All cover letters will include a hotline phone number to call if the homeowner feels appraisal bias has occurred.
“Chase is committed to maintaining appraiser independence and preventing attempts to influence appraisers in the preparation of appraisal reports, as well as avoiding any discrimination or bias in the appraisal process,” reads the letter.
This could be the beginning of similar settlements in the mortgage and real estate industry, as several cases of perceived valuation bias have popped up across the country in the past year. One couple in San Francisco – Paul and Tenisha Austin, who are Black – went so far as to have their white friends pose as the homeowners in order to get a better valuation.
Appraisal institutions have been scrambling to underline – or, in some cases, update entirely – their policies on appraisal bias as these cases have come to life. The Appraisal Institute, in fact, has said it will now require all appraisers to take a seven-hour course focused on Fair Housing laws and bias.
The Fair Housing Act makes it unlawful to discriminate in the terms, conditions or privileges of the sale of a dwelling because of race, color, religion, national origin, sex, disability and familial status.
Excellent. Having nullified the appraisal pressure hotline, instead there is a hotline for borrowers to call to apply value pressure to the appraiser for the specific purpose of forcing the appraiser to comply and hit the number.
Most lenders work with multiple amc’s, even though they have direct assignment elite appraiser panels they could turn to instead. Assignment platforms allow for selective or total appraiser blacklisting at the press of a button. Behind the scenes of automation are advanced tools that if an appraiser gets blacklisted anywhere, they are deranked and de prioritized in a variety of ways through the use of technical tools and sorting systems.
The people at the very top; HUD, TAF, Fannie, FHFA, have failed to understand what the real world situation is for every day working appraisers. Their apparent inability to recognize the devastating effects separation from loan production caused on small businesses, the billions of dollars of cumulative lost income and resources to the amc companies, the continued exodus of licensed workers whom will not be replaced. An average of 23 licensed appraisers has quit this industry every single day for the past 15 years (130k licenses relinquished / 15 years). The industry managers and policy setters exist under this illusionary concept that somewhere in the ever dwindling numbers of appraisers are a sub set whom will always play ball and make their deals work, if only they could thin out the lists a little bit more, starve the appraisers out for another round. There is no such thing as appraiser racism but there is definitely an over abundance of incompetent management, predatory lending practices, and deceptive junk fee billing schemes.
AIR FAQ. This document is officially worthless. Nearly every single tenet and guidance is violated on a daily basis as a routine industry standard.
https://singlefamily.fanniemae.com/media/21986/display
Data reporting correction. Sorry, my numbers have been incorrect regarding total licensees count. I remember reading appraisal specific articles about how many jobs have been reduced in this industry. Perhaps that was license relinquishment and ancillary help, must have been. Total appraiser head count figures for many years back. Pg 46-48. It’s not that as many appraisers quit, it’s how so many appraisers quit mortgage lending due to amc’s.
https://appraisalfoundation.sharefile.com/share/view/sf13f260546f149ab82622a87a8c94d23
Great news; Updated licensing proposals include having to retest to keep your license, or deal with licensing downgrades. And specific collegiate classes if appraisers fail certain exam topics. There is a survey all appraisers are supposed to take about this. Links in the Picasso article next article.
JP Morgan cares nothing about Appraisers and only themselves. Pay the Black homeowner $50,000 to shut her up. This action makes it LOOK like there WAS bias, no matter what they said in their letter. Settling means they are GUILTY! They cannot stand firm and pursue this to the end, to prove no bias and end the lawsuit because that means they have to spend more money. Hate JP MORGAN, always have.
Simple cost analysis. What is cheaper? Pay her off or got to court and risk poor PR. Deal with it right away, take a small stock hit and give 50K away. Then they will figure out a better means to thwart complaints from appraisal by denying them the application in the first place.
Quick how to life hack to get a refinance loan which is more than you could actually sell the property for in the real world; Accuse the appraiser of being racist.
Lender wins on both sides of the play; Higher commissions on the origination, larger write offs during the eventual liquidation or write down of asset phase. The consumer becomes captured in a debt trap, the gift which keeps on giving, servicing fees never end. Why bother with a repo when you can blow the market value sky high and retain the customer for life. ‘Appraisal modernization!’
Of course the GSE can’t get in the way of this and settle anything. Intimidating appraisers is back in style, imposed by imperial decree. The movement is driven by fear of the consequences and accountability for the federal reserve and the lending community having artificially propped up markets to the point where entire generations can no longer afford what used to be standard expectations, like housing, insurance, transportation, and food.
Back when this happened there were very few bias claims. Now that Chase told everyone they can get at least $50,000 just for going through the complaint motions they opened Pandoras box.
Im glad they had the integrity to NOT throw the appraiser completely under the bus.
With all this racist talked going on and me caught in the middle of it I want to transfer over to being a VA or regular review appraiser, that way I will never again be accused of being a racist, does anyone out there know how to get into a VA review job? I am a VA appraiser now. Or does anyone know of a opening for a review appraiser? Ken
They do in-house reviews by individuals who are employed by VA. To the best of my knowledge, they do not hire outside vendors.
Reviewer positions pop up every now and then on jobs boards. At least a few times every year. If they’re accessible or worthwhile positions is another story. Just get used to sorting away amc’s, as they constantly advertise to pick up staff appraisers and other menial low pay positions. Review jobs are going away too, because there is a substantial reduction in appraisal requests due to the mandate of FHFA to eliminate human appraisers from the lending process. For what is left much of that is moving to PDC hybrid so appraisers whom do stay will complete ten times the volume for even less pay, while personally shouldering the liability and scrutiny which would otherwise have been distributed among entire teams. Appraisal modernization is a code word for eliminating somewhere around 40,000 independent appraisers small businesses, possibly more.
Did you look up the GS-9 (starting) salary? Not the best unless you are in supervisory position GS-13+. VA has not stated their support for any of their appraisers in discrimination actions that I have heard of. They might confirm that a review, tidewater, or appeal was made; but I would not expect any more from them.
You are not alone in HUD problem. They have guidelines that they continually exceed without impunity. They tell you to respond in a certain time frame and let you know what timeframes they are operating on but continually exceed them and have the nerve to still use COVID as an excuse. Maybe they can blame Daylight Savings Time next.
Ken look up appraisers in the civil service General Service (GS) classification guidelines. They hire in at hte GS11 to GS 12 level (for VA Special Adaptive Housing Appraisers), plus local COLA depending on where they are located.
Do NOT think typical resume guidelines when filling out the KSAs. You can write a book if you need to. Follow the Guideline requirements for each pay grade. You find the jobs and applications at USAjobs.gov
Do NOT try to submit an application without carefully gearing your resume to the Classification Guidelines for that category and pay grade. Dont limit yourself to California. ALL you need to do is get your foot in the door for more than a year. Then you can apply at other agencies.
Two years experience = 1 year of college.
As I’ve written before, the scandal isn’t possible racism among appraisers, or false accusations of racism. The scandal is that despite 30+ years of state licensing, mandatory education, mandatory continuing education, state discipline, purported separation of lending production from appraisal, use of reviews and formalization of review processes, and all the rest – the scandal is that appraisals on a property can come in from $1.5 million to $3.1 million. How is it that appraisals and appraisal processes remain so shoddy that they can produce this wide variance in results?
Incompetence as with any other profession or, equally bad, undue influence. I don’t believe race played any roll but racism comes with a pay day.
The influence of the appraisal management industry having siphoned billions of dollars away from the general appraisal community which would otherwise have gone to career and skill development. Because of they way the amc industry and associated technical utilities involved with ‘grading appraisers performance’ which their future work load are based upon having created a new standard which rewards faulty appraisers simply because the appraiser charges less and finishes faster. The industry has experienced ongoing brain drain and professional skills reduction because of the pay to play systems, incompetent management programs, continuing education systems which rarely actually teach anything new, and lack of real world qualification testing to become an appraiser in the first place. A classic case of top heavy bureaucratic management where the managers are not actually qualified to do the work themselves. Stakeholder input…
You’re creating a straw man argument as if each individual appraiser is supposed to posses equivalent skills based on certain fixed characteristics of the industry as a whole. That does not fly when the best appraisers out there are consistently passed over for the cheapest and fastest. There is no review process per se, only after the fact accountability as originators approve literally anything to get their commissions, and the GSE’s refuse to use their own systems tools to correct faulty work products most of which are generated from the amc realms. This is due to the lack of reliable work flow patterns aka preferential appraisal assignment. From an appraisers point of view if you don’t play ball even one time the lenders click you off, the amc’s automatef systems prefer the cheapest and fastest appraisers. So it’s no surprise when real challenge work comes through the form fillers miss the mark. This is the fault of the lenders and unnecessary middle management companies, the deleterious effect they’ve imposed on appraisal product quality based on the ongoing temptation to drive appraisers fees down, drive consumers fess up, and pocket the difference without transparent billing disclosure.
Which is why the new standard is three out of four appraisers refuse to work with amc’s, despite the vast majority of all available work flow going through amc’s. Ethical knowledgeable appraisers would rather shut their own businesses down and suffer tremendous losses rather than work with such unethical unqualified companies and people. Where do all these stories of alleged racism keep coming from? You guessed it; The mortgage lending realm. That means there is always an 80% or greater chance the work product and oversight is negatively effected by the appraisal management industry, who controls over 80% of all mortgage lending assignments, yet sends them to a minuscule proportion of the total appraisal community. Of the twenty five percent of remaining appraisers whom still work mortgage lending, rougly half also still refuse amc engagements.
Vince in the example given Im sure it relates to the reverse mortgage aspect. RMs have routinely had cuts of up to 50% by the MANDATORY specific review firm reviews for years. Its why I stopped doing them over ten years ago.
All we get are the final numbers without being told the details. Did you know that on old VA appraisals for refinances, they NEVER appraised at MV if MV exceeded teh guarantee amount? They appraised at no more than the amount being requested. (My very first experience testifying (as an agent) arose from one of those cases).
The SCANDAL is that after 30+ years, the “Public Trust” is non existent despite all the manipulation to USPAP by TAF and “stakeholders”.
I was charge with racism through a VA loan and went through there protocol or their standard to investigate this. It took 9 month, my appraisal was reviewed by a staff review appraiser, then they had a zoom call with me that lasted about 3 to 4 hours. A few month later they cleared me, said I did have a few mistakes on the report which was caused by the homeowner not giving me the correct information in order for me to appraise the home higher, I did make slight mistake on measuring the home but again it was because the homeowner followed me every step of the way, we have all been there. I was cleared by the VA, they said the value I came in at was resonable and supported. They said that they have over 500 complaints now and raising nationwide.
Now HUD got that same complaint from the same homeowner (double jeopardy), it has taken almost 2 years now, the investigator who reviewed the appraisal and interrogated my on the phone with 6 1/2 hours of deposition, asked for 10 appraisals in white communities looking for racism of a different appraisal for white people, then said it was OK that I contact the homeowner when I told her that I might sue them, she encouraged the contact then wrote me up for harassment and coercion and informed the DOJ. HUD is after you, whereas the VA just wanted the truth and was respectful. Beware!!!!! I contacted the Inspector General’s Office of HUD and filed a complaint against the HUD investigator 4 month ago. Stay tuned.