Appraisal adjustments and scoring system method, new link. They changed the landing page.
http://www.patentbuddy.com/Patent/20150302419

Above link no longer worked. They adjusted the landing page.

Fannie Mae, Patent Owner, Washington DC

Closer and closer.

Mike, Class action !! All 30 million of them. We all know that we are required to those standards of USPAP, the AQB and a few more.

What is fair for us is fair for them. Just Saying.

Dave my respected friend, it’s a case of not seeing the forest for the trees.

FNMA has in house appraisers. It also has an automated process that performs the same function (appraisal AND appraiser quality reviews). It’s bound by FIRREA too.

USPAP doesn’t set state or federal law for appraisers. FIRREA did that. FNMA IS an entity engaged in FRTs. I think we are in agreement there.

The rationale for my claims are in USPAP 2018 definitions page 3, lines 59 through 84.

When CU started it was defined as a process for risk rating elements of an appraisal. It was a pretty marginal exemption or carve out even then. Many opponents claimed it WAS an appraisal review. FNMA side stepped it. FNMA  insisted it was not an appraisal review or appraiser rating system (old patent). Now (Oct. 2015 patent) it is a specifically patented process TO review the quality of appraisers work; AND to rate the appraisers overall  work quality; complete with penalties for bad ratings. It’s their own words Dave.

They can call it AQM all they want but when AQM adopted the processes that are currently used in FNMA CU 3.2 (and newer versions in the pipeline) it crossed over from being some kind of purely automated internal AQM to being outright appraisal reviews. FNMA even calls them appraisal reviews! FNMA further advertises 100% Reviewed reports now.

So next weeks task is merely to see what DC and TX laws say. I have a pretty good feel for what’s in Texas regs but need to check DCs too.

Check this out, I just retired too. It was this empty house with only a mirror at the end of a long hallway. Estate related. I tried not to look in the mirror.

Mike…I would invite you and everyone else to open their copy of USPAP, and read the first sentence on Page 1.  But to save y’all the trouble, it says USPAP establishes “requirements for appraisers.”  No one else is mentioned.  Plain and simple………..appraisers must comply with USPAP.  No other entity is mentioned or included.

Therefore, the various electronic review programs that have been developed by all kinds of entities have no obligation to follow provisions of USPAP.

Once the appraisal report leaves our possession, i.e., transmitted to the client, we have no control of what is done with it, how it is used, or who it is given to.

Appraiser’s Certification #23 ended that report ownership perception in 2005 when the forms were redone.

Article worthy. Let’s unpack this on a larger scale. Thank you.

Ten years later, I might actually know what I’m doing lately. Still not sure… According to the people I work with, I rarely do it right.

Thanks Mike! For the example and for the support. I had never had this happen before and it took me by surprise. It did not go to the state, but the fed agency that was the lender had my reports reviewed by their chief appraiser for 6 months. For that I did not mind because they had that right and I do what I’m required as an appraiser.

Dave, What on earth makes you think USPAP does not apply to them? USPAP is  a provision required under federal law (FIRREA) for appraisals performed in conjunction for federally regulated transactions…which by definition includes the GSEs. I Guarantee neither Texas nor DCs appraisal laws say “Everyone who performs appraisals or appraisal reviews for regulated transactions must be licensed …except FNMA.”

CU stopped being a simple QC or risk rating algorithm. It has become an outright review and appraisal rating system with appraisers being put on watch lists or exclusionary lists as a result.

We haven’t even touched on AIR DF violations BY FNMA! For too long appraisers just accepted that because FNMA is the one buying the loans that whatever they say goes. Does anyone seriously believe they aren’t doctoring the quality of many of the bundled securities they are selling?

FNMA does their auto review and when they type in the address of 67% of the properties appraised multiple appraisals pop up $180,000 to $220,000…which one do you think gets selected?

What’s the size of their human review staff today compared to 2 or 3 years ago? 1/10th?

Its all in how it is worded Koma. “The following agent and broker violated appraiser independence requirements of Dodd Frank in inappropriately attempting to coerce or intimidate me into revising my opinion of value.”[IF you want to pursue it; and especially if it was turned into a state appraiser complaint]  “As a result of your agency’s inaction I am filing a complaint with the state Auditor (or Inspector general). There is a difference between legitimate advocacy for their clients interests and prohibited practices under both federal and state regulations.

‘Further, I will be filing a formal Suspicious Activity Complaint (SAR) with FinCEN against the lender involved for their part in the prohibited actions. I’d never misrepresent a complaint to a state agency but neither would I count on them to ‘find’ the violation on their own. Spell it out for them the first time around and word it (truthfully) so that it is an unavoidable issue for them. cc Local MLS (if they shared mls data with bank), Banks regulatory agency, CFPB etc.’

Obviously It has to be specific to your case circumstances . Its frustrating to be brushed off like that. Don’t be discouraged. Just keep doing the right thing.

I know, Bill. Personally I don’t think any state has any business certifying an appraiser with less than three years experience. It erases any distinction between certified level of competency vs a license or permission to practice (and learn). People are different so I suppose it is possible in  2 1/2 to 3+- years too but at two or less years there is no way an individual could gain enough practical experience in the field to be considered for certification.

Sorry Mike………nice try, no cigar.  FNMA & FrMac can do anything they damn well please…………because USPAP does not apply to them, i.e., doing ‘reviews.’.  They can build and apply any kind of review system they want.

I’m with you on that one

I get it Mike. My point was that although most people seem to find this career later in life, some have made it a goal out of high school (recent). Those wanting this profession in 2014 (certified) are perhaps set to graduate this year (in debt $$$), only to learn with a change in policy that a graduating senior today can perhaps become certified in 1.5 years. Policy changes have real world consequences, but the powers that be could care less about the impact.

Seek the truth.

Baggs its your first one that is a smoking gun read the description

http://www.patentbuddy.com/Patent/20150302419 – Patent is for AN APPRAISAL REVIEW by any accepted definition today. Not exactly consistent with all their pre 01/15/2015 claims at all.

If they are rating the quality of our specific adjustments then they are conducting an appraisal review. My only question is do we file the state complaints for the 30 million non USPAP compliant appraisal reviews in Texas or Washington DC, where their headquarters is?

Institutionalized advocacy on behalf of vested interests. Betcha a hamburger that lender does not have salaried based loan officers. Latest FHA newsletter had link to the quarterly and yearly lender penalties, via federal registry. Some fines in the millions, no wrong doing, no admission of guilt. Fines based on income is obviously necessary, the cost of prosecution likely dwarfed the penalty amounts, amounts so low at times, lenders swat them off. And tens or hundreds of millions penalties, nobody goes to jail or is held personally accountable? Yes it’s true, they get away with it with no fear what so ever of personal prosecution.

https://www.gpo.gov/fdsys/pkg/FR-2018-04-25/pdf/2018-08669.pdf

I told a manager off a month or two back, suddenly no traction. Email me with details please. How does it work exactly, the informational flow, what is there, what is not, do lenders now go somewhere other than just the ASC website to verify appraisers credentials? Does one lender have the ability to influence other lenders decisions regarding individual appraiser choices in secret, unbeknownst to the appraiser? If we’re talking repeat events, they’re likely passing lists again. If FNMA is giving them that opportunity…