Of course. I should have known…

**these orders would be sent via Mercury Network

Sincerely,
Service 1st

Don’t get me started on that one! 1004MC was a joke on us…

Sounds like Pro Teck!

No joke.  They use April Fools day to wheel out new forms.  Remember the April 1st 1004MC.  Talk about a joke…that form was the ultimate.

Ken, Sadly it is not.

We ALL have only seven more days to read, investigate and respond (in a CONSUMER benefit perspective) to the following: (It was sent to me by someone in one of our federal oversight agencies).

“…  However, I thought it was important and did pass your email along to the banking agencies.  Evaluations are a hot topic right now as the banking agencies consider raising the $250,000 appraisal threshold.   I too have significant concerns about evaluations such as this Pace Pro product and evaluations in general.  The agencies are accepting comments on this topic as part of the Economic Growth Reduction Paperwork Reduction Act (EGRPRA) process that takes place every 10 years.  Comments can be submitted through the FFIEC website at http://egrpra.ffiec.gov. In fact, the agencies are considering comments on any aspect of federal banking regulations as they apply to appraisals. A list of those regs can also be found on the FFIEC website.  I encourage you and others to submit comments prior to the March 22 deadline.  Customary and reasonable fees is another important topic on which you can comment.  If you have any questions please do not hesitate to ask.”

I only added the bold face type. What they are NOT kidding about is RAISING THE DEMINIMUS level through the actions of a committee to reduce the paperwork burden!

The above may be the most important blog post affecting appraisers this year. I don’t think it is exaggeration to say if something is not done, it really COULD lead to the end of ALL residential appraisals for federally regulated transactions under $500,001.

Just who are the appraisers working for AMCs such as this? Reveal yourselves… traitors. And who is the AMC?

Appraisers are smarter than falling for this crap….right?

ACI is now touting how its automated reconciliation ‘feature’ now takes all the guesswork out of reconciliation within the sales comparison. It uses algorithms to weight each comparable sale BASED ON THE PERCENTAGE OF NET AND GROSS adjustments applied. Wow! What a handy feature for appraisers that don’t know their ass from a hole in the wall; and or those that cannot think of any more relevant way to “reconcile” within the sales comparison.

FNMA announced last year I think that they were abandoning the requirements or ‘guidelines’ to stay within 15% and 25% or any present net and gross adjustments since it appears appraisers are appraising to those guidelines rather than to market. Why would we then feel compelled to reconcile to, or based upon abandoned guidelines?

Mike Ford It appears that ACI is unaware of FNMAs telephone number, as well as not knowing THEIR collective arses from various and sundry holes in walls. Based on my 30+- years as an appraiser and eight years as a licensed real estate salesman may I be so bold as to suggest we ‘weight’ each comparable based upon it’s similarity to the subject as perceived by actual market participants and or overall validity as a valid indicator of market value for the specific assignment at hand, rather than one size fits all rote reconciliation.  That is no more valid than rote GLA or room count adjustments would be!

If YOU believe the N&G adjustments are the best determinant for weighting then that is YOUR decision to make and defend given the specific assignment, NOT some self serving software provider owned by other player interests in the mortgage market!

FAR MORE IMPORTANT (call just received): FFIEC.Gov under EGRIPA (I could have those initials wrong) which is a function of the  paperwork reduction act; is considering raising the deminimus lending level from $250,000 to $500,000 because the local community banks are complaining that they cannot find enough appraisers in rural America to handle the volume! If you do not write one other letter this year, THIS is one you should write.

We all know this has been a topic for discussion for over a year, but its coming to a head now.

The link to the agency is being sent to me soon. I’ll research it on my own as well but we only have DAYS to do this, not weeks. We need to write to them and point out the benefit/risk to CONSUMERS & taxpayers (they couldn’t care less about individual appraisers). THAT interest is appraiser competency versus the inability of Big Data or alternative products (evaluations or BPOS for example) to be a reliable alternative or substitute.

There is no shortage of appraisers as we have all noted. There is a shortage of appraisers willing to work for $25 a pop, for a BPO product review!

Without a shovel!