Valligent New $40 Alternative Valuation Assignment
Valligent, an AMC with ‘national’ presence, is soliciting appraisers to complete a new alternative valuation product on behalf of their GSE clients.
There is nothing wrong with doing these. Any appraiser can. But any appraiser who does these assignments is required to comply with USPAP’s Record Keeping Rule. Which means keeping a Workfile for every assignment.
In order to do these alternative valuation assignments, you need to comply with USPAP Standard 3, because you ARE providing a report review service. Even though Valligent is sly about not really revealing that aspect.
The SOW for these assignments, which I highlighted below, is actually absurd. Because, in order to evaluate the comparable sales, the appraiser will have to review the Subject Section in the report. You cannot make a decision as to the applicability of the comps in comparison to the Subject , unless you determine the subject’s characteristics first.
Here’s the relevant portion of the Valligent message, with my additional comments below:
The basis for this assignment is portfolio analysis leveraging the expertise of our panel to conduct a simple yet important analysis of only a portion of a prior appraisal report. You would be asked to limit the scope of your review to the comparable selection and the question of whether the comparables used were the best/most appropriate as of the effective date. No inspection is required, and no analysis of any other sections of the report are needed.
Client qualification requirements dictate that you must have prior experience appraising within the subject property’s specific zip code. As the results will be relied upon by the GSE, it is imperative that your knowledge of the immediate area be extremely thorough, and that the utmost care be given to your results.
Due to the limited scope of the assignment, a fee of $40 will be paid for each assignment. You will have approximately 2-3 business days to perform your analysis and finalize the report using the Acuity and Harmony platforms. It is estimated that each assignment will take approximately 20-45 minutes to complete, once you familiarize yourself with the requirements.
This is the key element of their Scope of Work:
“…asked to limit the scope of your review to the comparable selection and the question of whether the comparables used were the best/most appropriate as of the effective date.”
The other aspect of this kind of work for Valligent is in their appraiser engagement contract. Buried within, is the subject of Background Checks. Per their contract, they will deduct a minimum of $5.00 per assignment. However, it could be more depending of variable costs determined by your location in the US. So your net income may be something less than the $40 per assignment.
Bottom line: can you do these kinds of assignments? Yes. Will you want to do these? Who knows! It’s a business decision on the part of independent appraisers.
Remember, you ARE providing a valuation service (i.e., an appraisal) when you opine whether or not the ‘comps were the best.’
The Valligent message does not reveal the process if you decide the comps ‘are not the best.’ If you are expected to provide better ones, then you will be doing a full Standard 1 & 2 appraisals. And $40 is an absurd fee.
The GSEs are just trying to get a very limited report review done on the cheap by someone with a license and E&O insurance.
Dave Towne on e-AppraisersDirectory.com
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$40? Only if I can complete it in less than an hour and not have to leave my desk!
no way. i would never put a value on anything that i personally did not get to see. i have seen way too much fraud and corruption over the last 20 years to leave my guard down at all. the states and feds can try to over-regulate the profession all they want, but fraud and corruption will never go away completely. what they say is 100% true – same ol’ sh*t, different pile.
Anyone who puts their signature on a report for $40.00 is a fool.
May God have mercy on your souls.
How can the comparable sales be evaluated without a review of the subject?? How will the GSE’s compare the results to their big data CU database? The SOW is so limited, with possibly high liability, I would not go anywhere near this.
Wow, they found another way to screw appraisers and put us in jeopardy of being sued, all for a huge $40 bucks.
All the while they are probably getting $200-$300. Crafty little buggers (trying to stay above them with that word) aren’t they. Diana I agree with you except I think SCREW should have been in all caps…lol
Just complete 20 of these reports per day and you’ll be earning the type of fees you should be commanding in today’s market.
What, only 20! 🙂 🙂
Thanks Dave!
Think of it another way. Where we might be heading.
FNMA using Collateral Underwriter with 20 of their current predetermined comps they already have in their Datamine to judge appraisers by. Their next move (maybe), plug their own comps into their newly invented form. Get Broker Photo (usually done by newbie salesperson) that house is still standing. Salesperson uploads the exterior pic on their Iphone on site. Then “Presto”, instant value is met. The result, 24 hour turn around, $25 to Broker, and appraiser needed no more. Get the picture? Do ya think that may be where we are heading? (us lowly certified appraisers)
Years from now your name will be discussed by academics along with Nostradamus & Jules Verne. I mean that as a compliment too.
Sounds like this amc has found a way to compete with Stewart title (formerly AllonHill), and those likes. For those whom do not know those powerhouse names, they are portfolio review firms whom deal with troubled assets. In CO they were offering 30 an hour and better, straight up to any appraiser whom would be willing to roll full time in the office. Their average intake was over 100 to 200 per individual review, if I have understood their structure well. Disclaimer; I never worked there myself, but did look into them thoroughly when I considered a job option, and do know several appraisers whom worked there personally. / So what this amc is doing is marketing dynamic client leads, and is cracking into the portfolio review market with ‘innovative’ new methods and other such pr nonsense. Facts remain that forensic review is the most challenging type of review, regardless of the scope of work. It would appear that this amc’s ability to lay this out in a decentralized fashion may have been their winning sales pitch. Because companies like Stewart have central locations, and appraisers simply review remotely, using realquest or whatever that national quasi mls system is which lenders often rely on. Something coreillogical something or another. On the face, the decentralized approach looks great, but on the other hand, a limitation to the scope of work in forensic review may have unintended consequences. / My pertinent next question is; Can completing of these assignments affect an appraisers FNMA UCDP CU system approval? One certainly hopes so, because any appraiser moronic enough to sell their own future credibility down the river for these pointless products, deserves to be chopped off the vine sooner than later. There is another popular name for these products, from before this regulatory heat came on for portfolio review; BPO’s. This should not be a ‘business decision’ for appraisers, this should be limited to staff employee duty, and independent appraisers insurers should clearly state this is not covered practice. I’ll look forward to yet another undeserved insurance increase, when these fruitless half brain quickie reports come back to bite the purveyors of them. What a joke. And what do you want to bet that appraisers will outsource the typing duties on these?
Hey, I understand India is doing very well with our reports, are they reviewing them too? Wouldn’t be surprised if they are doing the forensic reviews too, I’m sure they charge a lot less than I do. 🙂
Because of jurisdictional considerations, privacy of reporting is not applicable to them. That’s why all these typing and amc services sprung up across the country lines. Definition of applicable client relationships has apparently gone by the way side, just like junk fee rules. Those rules are not applicable to amc’s. Prove me wrong, I double dare you try.
Sadly I think you are right. Similarly, definitions of appraisal have been tortured to the point of people believing day is night; black is white, and “I’ll call you in the morning, promise.”
Had a client switch to India and after the first time speaking to someone over there and them not understanding a lick of what I was saying, referring to my appraisal report, dropped that client like a hot potato.
Wait, I know this one! Quantrix to Corelogic? 2009 or there abouts? One day I was getting orders from a lady in Minnesota or a Northern state. The next day I was on the phone with someone whom sounded just like the Ocwen dudes I dropped a year prior. When I asked to speak to someone in the USA, regarding this order where the amc company switched owner and operations, literally mid stream of my order, They were impossible to work with, and that was that. Had several experiences like that now, supposed penalties on my ‘permanent appraiser performance record’ with these management outfits, just go poof and disappear when they need appraisers again. Smoke and mirrors, and outsourcing hype. If you want to talk about the problems with foreign companies penetrating our markets, note the issue specifically; The H-1B & H-2B visa programs. & STEM issues. Numbersusa.com has all the details on those issues. That’s happening in real estate, with worker displacement issues like that. How could you protect yourself if they did something illegal? They’re half a world away.
Dave I respectfully disagree with you (partly). Yes, I can physically and mentally ‘do these’. That’s not the same as saying appraisers can do them (in my state). I’ve had this discussion with OREA (now BREA). They said ANYTHING that is assigned to me BECAUSE I am an appraiser in California, MUST BE USPAP compliant; even hard money loan abbreviated appraisal requests, etc..
Another invention of cheap ass title companies! I used to work for one as Chief Appraiser. From as early as 1990, they have used their market clout and contacts to obtain, promote and market ‘less than compliant or accepted standards “appraisals” called something else.
Old Republic in Orange County was running an appraiser sweat shop for “reconciliations” (appraisal review products coupled with compromise guess-timates so the BPOs wouldn’t ALSO get tossed as worthless).
Read Dave’s description of this “product” closer. First off for all you get rich fast fans, the net fee is $35 or LESS!
I’m pretty good at writing up exclusions and assumptions and master agreements that provide for highly limited work on a case by case basis for special single entity clients, but even I can’t figure out how these could be made legal for an appraiser to do in California.
Forensic reviews and we are to offer an opinion that the comps were or were not the best available? Good luck complying with USPAP on THAT one! Another requirement is that the SOW must NOT BE SO LIMITED that the result is not credible. Conveniently overlooked by the AMC.
The REASON these are now being offered to appraisers at home via AMC is that the recent landsafe settlement has all the ones that used to maintain central offices and require appraisers to work THERE 6 days a week including Saturdays and from ‘before 8’ until as late as 8 or 9 ‘regularly’ all scared they will be the NEXT class action suits. They will!
The attorneys that were less than enthused about OUR fee appraisers C&R fee issues as independents are chomping at the bits to go after so called “independents” that were knowingly misclassified as 1099 workers when they were in fact legally employees subject to minimum wage laws.
ANYONE that used to do this email me and I’ll send you the attorneys name and email address that won the $36 million LandSafe/BofA settlement. Seriously. mike@mfford.com
Take the following scenario. You DO one of these. The AMC ‘client’ is one of those firms that buys defaulted and uncollectable defaulted notes and automatically files against the appraisers E&O! Most are going to offer low settlements just to make the claims go away and avoid litigation costs. Its already being done.
Let’s say that coincidentally one of these appraisal reviews with the non USPAP compliant “review” is of my work. I wouldn’t give a damn WHAT my E&O carrier said. I would absolutely hound you to the end of your days starting with a USPAP non compliance complaint against your state license; then in court; THEN on every social & professional media website I could find. I’d even have you added to at least TWO lender do not use lists where I know the owners on a personal and professional basis and do consulting work.
Is the $35 REALLY worth all that? I don’t even have to prove anything o the state! I just make the complaint and you get to take anxiety and acid reflux pills for the next year.
So, yeah, sounds like a worst case scenario. But on the other side of that, don’t some of these ‘conclusions’ drawn by quickie reports just get trashed or temporarily tied to some portfolio for something not risky to appraisers? Just to play devils advocate for a minute, but is it always that bad? And specifically please educate me on the line where the loan is classified as defaulted and collectable. Is that after eviction, after public trustee, or how does that work exactly, when the loan instrument is finally ported from a performing note to a non performing one, or even beyond that? I’ve read all about how mortgage fraud is related to those processes, loan servicing scams, clouded title and such, aka mers, etc. But I’m still trying to learn more about the details of portfolio management, and how that relates to definition of client and my EO. Can appraisers write in some line into the report which would protect from this sort of review? What is the current deal with the amc pre printed sow, vs the appraisers written engagement. I’ve got this clever; by using this report all parties agree, just an opinion, one time value service, no future services guaranteed, non transferable as of the date of value service, yada yada. I picked up those tidbits from years of apprsrs forum surfing, but the question regarding where does the appraisers influence on SOW begin and end, remained a contentious issue. Some argue the pre printed client SOW trumps. Some insist you have to cross out their SOW and add in some of your own every time like an official legal agreement per individual order. While others argue the appraisers write in language within the report itself, although client presented SOW was not altered, can be protecting and binding in sticky legal scenarios, perhaps like the ones which could come from your origination reports being reviewed by default management agencies or post review, and the likes of this article topic? I do appreciate the detailed information presented here from everyone, thank you.
Baggins, all great questions and observations!
Um, you SURE you want ME to try to provide responses? Im not known for brevity and we could lose the entire blogs readership if I try.
OK, Y’all had fair warning! The smart ones are already nodding off and napping.
“Portfolios” represent SOMEBODYS investments, or money. These are people that make BILLION dollar decisions in seconds or minutes. They rely on the validity of what they are being told. Example; when FNMA offered their last $756 BILLION in defaulted loans, I mentioned it in passing to a ‘facilitator / International broker’. Five minutes later I was told to find out the details and 15 minutes later while I was still reading about the nuances, HIS “money man” was on the phone to the middle east to people that don’t even answer their own cell phones; and that live in palaces (seriously). Decision was made between this investment and another $300 million over priced investment with a mental coin toss. This one lost out-mainly because of all the strings attached to the deal by Congress and regulatory agencies.
The POINT is that is how fast these things are decided. You and I are so far down the feeding chain, no one will ever know who we are UNLESS we are wrong and provided one of these BS, misleading forms that helped them make bad decisions (collectively).
Is ONE bad reconciliation going to upend the earth? Probably not. “Whats the harm”. Exact same questions I used to hear from our in house mortgage brokers in 2005-2006 and even into 2007 when I kept killing their refi deals and they were trying to get the ok to order outside appraisals. Did any of MY appraisals go bad? Probably. But I’ve never heard back so I am assuming the extra effort to remain USPAP compliant (as is required in my state even for NON federally regulated deals) paid off.
(Anyone still awake?)
Default point is always different from determination it is uncollectable (or systemically written off). Default date is date they became delinquent. All fees and costs from this date will be in final claim amount. Notice of Default (NOD) is the date legal notice of default was declared.
Now, at some point early on IF the lender fails to foreclose they COULD void their loan insurance so even if they ‘wanted’ to help, they may not be able to do so from either a business perspective OR a legal one. Under the various bail out programs, all this can be changed or modified but you can bet no one voluntarily surrendered their right to collect the top 25% of loss from MMI or PMI. So, it gets foreclosed and note holder gets their 25%; now they sell the property and only get 50% of balance owed back. Traditionally if foreclosure was in a Trust Deed state, they are done, finished kaput! BUT in recent years there have been more judicial foreclosures versus Trustee Sales.
THOSE MAY have deficiency balances that ARE (theoretically) collectable depending on the state the property is in. Each step of the process required certain due process actions that a lot of banks skipped or failed to perform because they never had all the paperwork in the first place. People at every step in the original loan and note sale all kept saying:
“What’s the worst that could happen?”
The French, Dutch, British, Saudi, Belgium, Chinese, German and Bopubotswanna investors are PEEVED!
“Whatdayamean all we get is doodly, and how much in Euros, Pulas or Rand or is ‘squat’ anyway?
“OK, what about the million dollar E&O all the idiot appraisers carry? This PACE PRO thingy isn’t even good for toilet paper. Go sue those baaaaad appraisers!”
OK, I confess. I made that last part up. They’d say naughty, not bad.
OK we lost everyone. Shhhh. They’re sleeping. We’ll cover the rest later if you are still interested.
…besides if I’ve gotten others to go with extreme long posts, then my job here is done! Another success. *G*
I know all about the Landsafe settlement Mike (first hand) as my previous trainer just cashed a $130,000+ settlement check. Depending on several categories, work performed, the state you live in, time worked, etc., the amounts varied, however in speaking to them the average settlement amount was $64,000. The last regional meeting that I’m aware of Landsafe/BOA had prior to being sold, was catered with pizza and the settlement issue was never brought up. Leave it to the corporate world to throw a party worthy of a 7 year old birthday celebration, while knowing they will be paying on average $64,000 to each of you in a few weeks/months.
You could make a better living selling popcorn. Idiots……..
My latest quip is this; When the process clerks earn more than the licensed professionals completing the work, there is an obvious problem with compensation distribution. / And my standard position on these matters; You’d have been better off at the credit union. / Mike, I’ll probably stop asking as detailed questions, because it’s quite difficult to unlearn something learned. And you just ruined my day again, with plain old facts. LOL. One ponders why the gse’s are still in place, given their departure from their original mantras. As usual; it’s important to always mention the gse’s, although federally chartered, are private corporations at the heart. Having departed from their original mantra, having been dabbling in hedge funds, having accepted mers, having played the continuing shell game, positioned to help the interests of lenders over the interests of American citizens, it’s obvious they are no longer on par with the permissions granted through their original mantra. If investors get fed up with this activity, they merely need to redirect capitol to private in house lending like credit unions instead. So rather than purchasing huge lumps outright, it would seem the investors would be better served by extending capitol, and waiting for the customers to present themselves, rather than buying existing packages. The plain truth is too many people are borrowing, instead of owning completely.
“Ummmm, What HE said!”
Yeah boy! What you said! Like, how long will this continue before these quote unquote sophisticated investors, actually demonstrate sophisticated decision making process? They’re like overly invested in automation and data aggregation analysis, if you ask me. Some old fashioned bricks and mortar lending solid capital, at solid rates and solid service, would go much further towards stable portfolio investment, than trying to buy gse sourced loans. You know how rich people behave though, they’ve got to have it, and they’ve got to have it right dang now. The portfolio investors inability to extend capital prior to loan sourcing, continues to be their downfall. As long as they play the portfolio game like trading baseball cards, the gum will continue to be stale. If I had a billion dollars, I’d develop a hundred thousand 900 sf brick ranches w/ 1 car garages on .12 acre plots, run modern green tech benefit for every home, and flip them all out non investors for a set uniform price. The whole project would presell within a year. Nobody really want’s to solve the ‘housing crisis’. LOL. Chaos by design is tiered pud building strategy, if you ask me.
Hah!
PROVED I can do brief! (…now there will be NO MORE OF THAT!)
Baggins, the investors won’t go elsewhere when the investment is fully insured, AND where the full faith and credit of the American People can be relied upon to make sure that even foreign re-insurers of AIG, like Societe’ Generale in France will be protected against bad, dishonest, fraudulent and or incompetent decisions made by Wall Street, FNMA, Freddie Mac and all the others.
Ah, ya gotta LOVE the American Taxpayer. No matter how big the burden, we’ll keep coming back and asking for policies that will keep putting more straws on our backs.
The sad thing is that the ‘system’ could work so well with plain old honesty applied to it!
WHEN did we decide that hard work, integrity, human understanding, professionalism and competence could be put in the back seat behind opportunism; cronyism, subterfuge, sophistry and outright FRAUD?
When did the knowing the difference between right and wrong get shoved aside for expediency? Is EVERY single thing I was taught about values; integrity, self respect and even patriotism a lie?
I will NOT accept that!
Now you just got political. Answering those points would certainly lead us off topic, and the posts would distract. Luckily, people are looking at these fundamental changes in the USA, and they’re constantly looking into the details. God is a frequency within you, ‘tune in’. / http://tunein.com/radio/KHNC-1360-s16926/
Only idiots will do these. You get exactly what you pay for in this world. This blog is even wasting my time.
The biggest part overlooked by appraisers… the product states several times that you are not commenting on value, but that is not possible if you are agreeing/ disagreeing on comps, selecting new comps, and including your search results for similar sales – those actions all use the appraiser’s judgement and result in value ranges. But the product is being offered with the hope that appraisers don’t realize they need to meet Standards 1 and 2. I emailed them back, and the representative provided more explanation of how the RA isn’t commenting on value (but in reality you are). I emailed two higher-ups in the company, honestly reaching out to discuss the compliance issue (not confrontational), and never heard back.
I don’t know if it was this article or a common trend or what, but one of these default management focused amc’s whom had been promoting a cheapie $25-$40 product, suddenly switched gears on me. They jumped from repeat emails trying to garner appraiser interest and build up panel of appraisers willing to engage with their new cheapie products, to suddenly letting off. Just sent me 2x reo full inspection orders out of the clear blue, at $390 each. It is tough to do reo though, because every home has some evidence left of a broken home, or broken dream. It’s always a little sad, but then again, so is mortgage origination when you see the borrowers treating their homes like atm machines and repeatedly renewing 30 year mortgages. Anyways I’m stoked, because those orders are easy to fit in, and it’s relieving to know these default management companies are not going to make headway with cheapie quasi bpo solutions, and at least one of them, just returned to full reo inspection ordering. You know the companies whom are promoting the cheapie products are having a tough run with it, when you see that same promotional email over and over. I have responded with the details of ethics, quoting this and that, but that’s over their head anyways. In this day and age, the appraiser needs to function as the quarterback for many concerns, because the people assigning the orders are both unaccountable, and not properly experienced to be effective stewards of orders being placed for professionally licensed appraisers. “Thanks for thinking of me with this order. However, I only complete this kind of work as 2055 or 1004 full, or GP form full. I’m not touching any reo for anything less than $400.” 2 years later, back to fulls. It’s a game of attrition and patience these days. I read a lot about appraisers holding fast and holding the line, but that’s too old fashioned to keep up with these dynamic flip flop approaches the clients use lately. Roll with the punches, and play the same game of substitutability they play. I’m off of the whole amc boycott, because some of them are using cost plus, fixed rake, and removing the financialized incentive to utilize discount services. And if they still run on the margin of variable rake, that spells out more dollars to me, and I make sure to bid high for those types. They’re still goons for grading, but you just play the field and keep on throwing high fee hail mary’s. You will score a high fee touch down eventually if you keep on running your special teams down the field.
Josh, they usually aim these toward less experienced, non certified appraisers that simply do not know any better. Those that are struggling; cant find a mentor and who believe other ‘staff’ appraisers that work for companies like these that the ‘product’ Is ok. I’ve even had them tell me that if the software company isn’t going to invest a lot of money and create these forms if its not ok to use them!