The push is on to eliminate the need for an appraiser.

Things are busy, but not crazy due to a lack of inventory. Is anyone interested in getting together for lunch? Send me your thoughts.

I haven’t put out many emails in the last year in part due to some computer issues messing up my email list and the fact that there have not been too many bad things happening in the appraisal industry lately. That is amazing. If you know someone that is no longer getting my emails, let me know. I had to piece things back together and I am getting some kicked back as spam. When I have time I will try to get things figured out to get the emails going the way that they should.

The shortage of inventory is doing a number on buyers out there. Folks are starting to get a bit crazy in their attempt to get a house. We now have a new phenomenon of the weekend listing. Listings fell 11% from last month. You may see things in the MLS notes of “no showings until Saturday. Offers being presented on Sunday”. That is how crazy it is. Sellers in the first time home buyer market can go away for the weekend and come back to a pile of offers to choose from. The competing offers are hitting $10,000 or $20,000 over asking price and the buyers feel justified because that is the only way that they can win the bidding war. The question is this going to relate to market value? Is there some duress in the auction setting? Home owners seeing the feeding frenzy may become motivated to put their homes on the market to take advantage of demand. What happens when rates go up? Will they go up? The Fed says yes, but they seem to have gone down. Lenders have tightened requirements but are pushing to eliminate the need for appraisals so they can do more loans faster. Appraisers keep slowing things down and coming in under contract price.

One question is how will this affect risk for the lenders and what is this shortage of supply going to do to borrowers 5 year down the road when demand is down and rates are up. Will the lenders come back on the appraisers questioning why the homes were appraised so high 5 years ago like they did in 2008 and later. If the market is paying higher prices that would relate to market value. How will this year compare to next year?

There is an appraiser shortage, so let’s eliminate the need for the appraiser and make things better.

That is what I have been hearing from the GSE’s and AMC’s. I keep seeing and hearing about all of these moves by the major players to change the appraisal industry (Modernization they call it). Fannie and Freddie both changed their requirements for licensed appraisers to do inspections of properties for certain loans. There is a push to put out property reports where they send a person out to take pictures of the subject and then an appraiser uses the AMC’s AVM to analyze the market and choose some comps and give a value. There is a video below about a Value Net appraisal. It shows all the reasons not to use a real appraisal. There is also a link to an example of one.

They always seem to miss the elephant in the room. What about paying reasonable fees? What about eliminating AMC’s continual bombardment of revision requests? What about eliminating excessive AMC fees? What about eliminating AMC’s? There answer always seems to be to eliminate the appraiser.

https://www.fanniemae.com/singlefamily/property-inspection-waiver

http://www.freddiemac.com/learn/pdfs/uw/hve_fun_guide.pdf

The VA had a hearing speaking to appraisal related representatives about how to make the industry better. It is good that those in charge are asking questions finally about why appraisers are getting out of the business. You can listen to Phil’s comments on the Voice of appraisal broadcast. The speakers include Mr. Jeffrey London Director Loan Guaranty Service Veterans Benefits Administration U.S. Department of Veterans Affairs, Mr. Gerald Kifer Supervisory Appraiser Loan Guaranty Service Veterans Benefits Administration U.S. Department of Veterans Affairs, Ms. Michelle Bradley 2016 Real Property Valuation Committee Chair National Association of Realtors, Mr. Stephen S. Wagner, MAI, SRA, AI-GRS Vice President Appraisal Institute, Mr. Russell Johnson Chief Revenue Officer Clear Capital – See more at: http://veterans.house.gov/calendar/eventsingle.aspx?EventID=1666#sthash.hCy2I8zK.dpuf

Clear Capital was pushing the desktop appraisal at the hearing with a professional photographer doing the inspection.

The complaints include:

It takes too long to get an appraisal done.

It cost too much.

There aren’t enough appraisers.

The number of appraisers is declining.

Rising revision rates.

Appraisers are killing deals.

Delayed Profitability.

Frustrated borrowers.

Poor Quality.

Fast forward to about half way through because the video doesn’t start until then.

http://veterans.house.gov/calendar/eventsingle.aspx?EventID=1666

November Congressional hearing on Modernizing Appraisals.

https://www.youtube.com/watch?v=_XwhTQsguYI

Sample Value Net Appraisal

http://www.valuenet.com/

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April 11, 2017
The new Fannie Mae Appraiser Update keeps you on top of the latest appraisal newsHow do appraiser-related policy updates, technology changes, and industry trends affect your business? To stay on top of the latest Fannie Mae appraisal news and policies, check out the new Fannie Mae Appraiser Update, a newsletter providing periodic updates for residential appraisers serving Fannie Mae lender customers.

Our first issue covers Day 1 Certainty™, including Property Inspection Waivers (PIWs) and certainty on appraised value, Collateral Underwriter® (CU™) stats, and Selling Guide updates relevant to appraisers. Whether you’re a field appraiser or work for an appraisal management company or lender, we have the information to help you effectively serve your clients.

Read the March 2017 issue and sign up to continue to receive the Fannie Mae Appraiser Update and other appraisal-related news.
https://www.fanniemae.com/content/news/current-appraiser-newsletter.pdf

 

The government says that customary and reasonable fees are anti competitive and the Louisiana state appraiser board are gangsters.

I thought I would send out this latest news on customary and reasonable fees. So far I only have one response about lunch and that is that it be on a Tuesday or Wednesday. I know school will be getting out soon and graduations will begin, vacations will start. Work is steady and we will be seeing a bubble form in our market, but there is time for lunch this month. Can I get a show of hands of anyone who wants to meet?

The thing that we are not allowed to talk about and nobody wanted to do anything about is being challenged because someone did something about it. Louisiana is being charged with racketeering for doing what the Dodd Frank act told them to do. And to think I was just getting used to nothing bad happening in the appraisal industry.

https://www.ftc.gov/news-events/press-releases/2017/05/ftc-challenges-louisiana-real-estate-appraisal-board-regulations

2017 I Predict

It is a new year and the plethora of appraisal orders have dropped of significantly since Christmas. That appears to be due to Donald Trump getting elected, causing rates to go up ½ a point.

Last year was relatively uneventful as far as bad things happening in the appraisal industry. There was a lot of controversy over the issue of whether or not there is an appraiser shortage. The consensus by the appraisers is that there is not a shortage, just a shortage of appraisers willing to work for AMC’s. The other people seem to want to believe that there is, kind of like that appraisal buzz survey saying that the thing appraisers are most worried about is appraiser fraud. Now the GSE’s are moving toward no appraisal loans as seen in the article links below. In order to save money and time, I predict that there is going to be a big push this year to eliminate appraisals by using big data instead.

They could also save money by eliminating AMC’s. One big question is how much work will there be this year with rising rates and the GSE’s decreasing the need for appraisals.

Showings have started out robust for January and there is still a lot of demand for home purchases. I predict that the Dane County market will be similar to last spring with competition for homes as people attempt to buy a house before rates decrease affordability. The refi market will drop of as rates increase.

Freddie Mac would like to make traditional appraisals history (Washington Post)

Can computers, big data and advanced analytics replace real live humans when it comes to accurately valuing the house you want to buy? One of the two largest financial players in U.S. real estate thinks so and is preparing to introduce changes that could prove momentous — and highly controversial.

Giant mortgage investor Freddie Mac plans to dispense with traditional appraisals on some loan applications for home purchases, replacing them with an alternative valuation system that would be free to both lenders and borrowers. The company confirmed to me last week that it may begin the no-appraisal concept as early as next spring. Instead of using professional appraisers, Freddie plans to tap into what it says is a vast trove of data it has assembled on millions of houses nationwide, supplement that with additional, unspecified information related to valuation, and use the results in its assessments of applications.

Fannie Mae

Enhanced Property Inspection Waiver Frequently Asked Questions Updated November 28, 2016 Property inspection waiver (PIW) is an offer to waive the appraisal for certain refinance transactions. PIW offers are issued through Desktop Underwriter® (DU®) using Fannie Mae’s database of more than 20 million appraisal reports in combination with proprietary analytics from Collateral Underwriter® (CU™) to determine the minimum level of property valuation required for loans delivered to Fannie Mae. Effective December 10, 2016, an enhanced PIW offering will be available to all lenders via DU. This summary is intended for reference only. All criteria are subject to the formal terms and conditions of the Fannie Mae Selling Guide. In the event of any conflict with this document, the Selling Guide will govern.

Which transactions are eligible for consideration for a PIW? The PIW offer will be considered on the transactions below: § One-unit properties, including condominiums § Principal residence, second home, and investment property transactions § Limited cash-out refinance transactions up to a 90% LTV/CLTV for principal residences and second homes; up to 75% LTV/CLTV for investment properties § Cash-out refinance transactions up to a 70% LTV/CLTV for principal residences; up to a 60% LTV/CLTV for second homes and investment properties § Loan casefiles that receive an Approve/Eligible recommendation Purchase transactions and the majority of refinance transactions will not receive a PIW offer, which means they will require an appraisal by a qualified residential appraiser to establish the market value. The following are not eligible for a PIW offer: properties located in a disaster-impacted area; purchase, construction, and construction-to-permanent loans; two- to four-unit properties; loan casefiles where the value of the subject property provided to DU is $1,000,000 or greater; HomeStyle® mortgage products (Renovation and Energy); DU Refi Plus™ loan casefiles; leasehold properties, community land trust homes, or other properties with resale restrictions; cooperative units and manufactured homes; DU loan casefiles that receive an ineligible recommendation.

Congress finally listened to some of the issues in the appraisal industry. I wonder if any of those guys got re-elected? Donald is going to get rid of Dodd Frank. I wonder if that will fix the AMC issues? Will he want to replace it with something better? What will we end up with in Health Care? Something affordable? I am sure it will be big league, amazing, fantastic, super classy, and something terrific.

Donald Trump on Budget & Economy

I predict that the next big change will be the appraisal forms. They will answer all of the questions that GSE’s want answered and will be filled with big data analytics. The data will auto fill the forms and the only work that the appraiser will do is choose the data. The software company that comes up with this will be the leader in appraisal software.

I have a new website for real estate sales if you want to check it out. I will be adding more to it in the near future. Let me know if you know anyone who wants to buy or sell a house this year.

http://dsmith.starkhomes.com/

Dave Stark’s quarterly newsletter that just came out. He always has a good analysis of what happened in our real estate market and a prediction on what is to come.

http://stark.media.active-clients.com/files/rich_content_company/370/373/File/

NAMB president thinks appraisers make $250,000/year as a trainee.

Here is a post from the National Real Estate Post with the President of the National Association of Mortgage Brokers Fred Krieger. He says that appraisers in Portland Oregon are getting $1,200 to $2,500 for appraisals and he thinks that a new appraiser makes $250,000/year easy. You would think that the president of NAMB would be from the planet earth.

http://thenationalrealestatepost.com/namb-pres-addresses-appraisal-epidemic/. He is glad that Fannie Mae is going to waive the requirement for an appraisal on a loan. I am also getting the impression from watching DC RESource, the mortgage industry thinks that we are gouging consumers. It sounds more like they are getting gouged by the AMC’s and do not even know it. Nobody wants to talk to the horse, the appraiser. Even in the talk to congress, they put most of the blame of the market crash on unscrupulous appraisers. It could be the greed of the lenders, willingness to lend to anyone who had a pulse with a loan laden with fees and a penalty for paying off a loan early, and an coercion to manipulate appraisers who were only making $250 an appraisal.

 

Appraisal Gouging says appraisal fees in the Rockies are as high as $2,620. It must be time to move out west.

He also says that appraisers are trying to purposely damage AMC’s by holding orders for a month and then telling the AMC that they never accepted an order. Everyone wants to blame the appraiser for the industry’s Insanity.

http://thenationalrealestatepost.com/real-estates-greatest-challenge-2/

 

Take time and read the comments after the videos and hear the appraisers responses.

The future of the Appraisal Industry. Overhaul or Destruction?

All of a sudden after 8 years of destruction of the appraisal industry, congress finally listens. Will they do anything? We are down to 7,900 licensed appraisers in the country. Finally after 8 years the appraisal institute went before congress to discuss the over regulation and excessive requirements of the appraisal industry. There are some excerpts from the meeting on the recent voice of appraisal. The attachment and link is a summary from the appraisal institutes view on the subject.

You can also watch the whole thing at http://www.theresource.tv/homepage/modernizing-appraisal-industry-dc-weighs/ It is the second video and you might want to forward to the part where people are talking.

The call is for total change of how things are run. It’s worth watching! Send this out to other appraisers.

Eliminate bank owned AMC’s and AVM’s.

Items in the summary include making appraisers pay for AMC regulation, fingerprint and background check requirements,

How the supervisor class requirement is worthless.

The continuously changing of USPAP instead of only changing it when it needs to be changed. If standards were well written they would not need constant changing.

The TAF requirement to pay $75 for USPAP as well as the $40 per appraiser fee given to the ASC and the continuous requirement to purchase it every time it comes out.

New rules  expected to be finalized next year by the ASC will expand the agencies budget on the backs of appraisers.

There are 2 appraisers supporting examination functions in all 3 major examination agencies.

The impact of AMC’s on appraisals.

The GSE’s UAD and seller/services guidelines drive the appraisal process and are used to judge the appraisers. Appraisers are not given any input into the forms, which reduce quality and are in need of change.

Adding AMC fees covertly into appraisal fees on consumer disclosure documents.

The lack of a requirement for an appraisal to get a loan.

Fannie and Freddie have not gotten the guidelines right.

http://www.voiceofappraisal.com/

http://financialservices.house.gov/uploadedfiles/hhrg-114-ba04-wstate-wgarber-20161116.pdf

The NAR also submitted their view on the appraisal industry at http://narfocus.com/billdatabase/clientfiles/172/1/2787.pdf

Appraiser Lunch and Changes to Changes in the Appraisal Industry

Even Though I received about 20 orders last week, showings are declining as usual and things should let up a bit around the holidays. There was some interest in lunch the last time that I asked, so I am just going to schedule a lunch date for Thursday November 17th at noon at Legends on Grand Canyon Dr. That is the week before Thanksgiving and 2 days before deer hunting. This would probably be the last chance this year unless you want to wait for some time before Christmas. I was also thinking that if it would bring more people to lunch I would offer to show how to use the MLS importer in alamode for Total users who have not taken the time to figure it out yet. Legends isn’t the best venue for a class, but I could bring in my computer and give a brief explanation on how to use it. Let me know if that would help some more people make it. Please RSVP on lunch so I know if anyone else will be there.

It’s November 1st and I wash and waxed my car outside today. Absolutely wonderful weather. There is still a lot to get done before it snows. I did not accept any of those orders last week so I could get some things done before it gets too cold. I already have 4 appraisals to do. I still have a lot to get caught up on. I just love this 2 week turn around time. It makes it a lot easier to fit life in to the schedule. I think we should do something to make this the AMC industry standard instead of the 48 hour TAT.

I have included a few things that you can take a look at. I would have done a little more research on the FHA changes if I had more time, but I wanted to get the lunch thing out there so you all can put it in your schedules.

The most striking things in the appraisal industry lately has been those in charge of the appraisal industry are making changes to their changes. In September HUD sent out some revisions to the changes they made. Their document doesn’t make it easy to figure out what exactly they changed but one seems to be the home inspection appliance inspection.

The ASB is thinking about changing the definition of a report and they want your input.

The AQB is talking about changing the appraiser requirements they just changed and lowering the requirements to become an appraiser in both experience and education. Maybe they think there is an appraiser shortage. The easiest to increase the number of appraisers would be to stop making dumb changes all the time and stop letting AMC’s and GSE’s run the show.

One of Fannies newer requirements is that we explain how the comps were weighted and which one we put most weight on. Even if all 6 comparables adjust to with in 1% of each other you still have to pick one according to the AMC’s.

I think someone should address the elephant in the room. I think we need a form change because I get the feeling that the current forms do not answer the questions that the lenders want answered. The subject neighborhood rarely has anything to do with the market and it seems more logical to be defining the market than the neighborhood. The lenders do not really want to know what the house will be worth on a specific day before they even make a loan on it. They want to know what it will be worth when the borrower loses his job and can’t make the payments. The market conditions addendum doesn’t really tell you that much. If they broke down every time period into the same 3 month increment and went back 3 years there might be enough information to see a trend that repeats itself. If they are going to have it in the appraisal, it should be part of the form. Why not build in extraction and allocation charts into the form based on the comps and the market search? I am sure you all could think of some good changes to make.

 Proposed changes to REPORT definition in  USPAP

The ASB is proposing changes to the definition of a REPORT.

Currently the USPAP definition of a REPORT is: any communication, written or oral, of an appraisal or appraisal review that is transmitted to the client upon completion of an assignment.

The proposed definition identified in the ASB second exposure draft for changes to USPAP 2018 – 2019 defines a REPORT as: any written communication, of an appraisal or appraisal review that is transmitted with a signed certification the client or party authorized by the client; or any oral communication of an appraisal or appraisal review that is transmitted to the client or party authorized by the client in an assignment for which a written report is not transmitted.

The second definition also impacts on the RECORD KEEPING RULE; if it’s not a report are you required to have a copy in your workfile?

Food for thought; Who benefits from this change? Will the proposed changes create an environment where unscrupulous mortgage originators or AMCs ask for a draft in order to shop for the best appraisal? Are there other unintended consequences?

This is an important change, so please review the change and communicate with the Appraisal Standards Board and share your thoughts. Second Exposure Draft of Proposed Changes and Exec Summary for 2018-2019 USPAP-Final

Fifth Bank Failure of 2016

What a difference a few years make! 2010 saw 157 bank failures, more than at the height of the savings and loan crisis. A few years later we are down to only five bank failures so far in 2016.  That’s progress. This past month state regulators closed down

Read more…

There has been a lot of talk about the falling homeownership rate in the United States. In December 2004, the homeownership rate reached an all-time high of 69.4%, while the current rate is 62.9%. When comparing these two figures, there is some room for concern regarding the difference.

However, today we want to shine some light on the issue by:

  1. Showing what historic homeownership rates have looked like over the last 130 years.
  2. Breaking down the current percentages by state.

Percentage of Homeownership by Decade and by State

Latest AQB Proposal on…

By proposing the elimination of the Bachelor’s degree requirement, the AQB seems to be listening to the consensus of many…

http://www.workingre.com/latest-aqb-proposal-on-college-degree-experience-requirements/

Raise your fees and pay your bills.

Do Your Fee Math (and Raise Your Fees)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

II.A.3.a.ii(F) Requirements for Living Unit; II.D.3.e Appliances Clarified definition, standard, and reporting requirements for appliances. 164, 500-501

 

II.A.3.a.ii(P) Individual Residential Water Purification Systems; II.A.6.a.viii(A) Monthly Escrow Obligations; II.D.3.p.vi Individual Residential Water Purification Systems Added guidance for individual residential water purification systems. 170-173, 341, 511

 

II.D.3.c.iii(C)(7) Stationary Storage Tanks Revised language about stationary storage tanks and MPR/MPS. 490

 

II.D.3.c.iii(C)(7) Stationary Storage Tanks Revised language about stationary storage tanks and MPR/MPS. 490 II.D.3.g Mechanical Components and Utilities Updated language for appraisal of mechanical components and utilities. 501 II.D.3.g.iii Plumbing System Clarified language for appraisal of plumbing systems. 503

 

(c) Use of Appraisal Management Company or Third-Party Contractors The Mortgagee may engage an Appraisal Management Company (AMC) to perform services related to the obtaining of an appraisal. The Mortgagee remains responsible for the acts of its AMC or third-party contractors. The Mortgagee may not pay the AMC and other third-party contractors fees in excess of what is customary and reasonable for such services in the market area where the Property being appraised is located. Any management fees must be for actual services related to the ordering process, or review of appraisal for FHA financing.

 

(d) Appraiser Independence The Mortgagee must ensure it does not compromise the Appraiser’s independence. The Mortgagee may not allow the Appraiser to be selected, retained, managed, or compensated by a mortgage broker or any member of a Mortgagee’s staff who is compensated on a commission basis tied to the successful completion of a Mortgage or who is not independent of the Mortgagee’s mortgage production staff or processes. The Mortgagee must ensure that it does not: · compensate the Appraiser at a rate that is not commensurate in the market area of the Property being appraised with the assignment type, complexity and scope of work required for the appraisal services performed; · withhold or threaten to withhold timely payment or partial payment for an appraisal report; · prohibit the Appraiser from recording the fee paid for the performance of the appraisal in the appraisal report;

 

Standard The effective date of the appraisal cannot be before the FHA case number assignment date unless the Mortgagee certifies, via the certification field in the Appraisal Logging Screen in FHAC, that the appraisal was ordered for conventional lending or government-guaranteed loan purposes and was performed by a FHA Roster Appraiser. The Mortgagee must ensure that the appraisal was performed in accordance with FHA appraisal reporting instructions as detailed in this SF Handbook and the Appraisal Report and Data Delivery Guide. The intended use of the appraisal must indicate that it is solely to assist FHA in assessing the risk of the Property securing the FHA-insured Mortgage. Additionally, FHA and the Mortgagee must be indicated as the intended users of the appraisal report.

 

(ii) Restriction on Resales Occurring 90 Days or Fewer After Acquisition A Property that is being resold 90 Days or fewer following the seller’s date of acquisition is not eligible for an FHA-insured Mortgage. (iii)Resales Occurring Between 91 Days and 180 Days After Acquisition A Mortgagee must obtain a second appraisal by another Appraiser if: · the resale date of a Property is between 91 and 180 Days following the acquisition of the Property by the seller; and · the resale price is 100 percent or more over the price paid by the seller to acquire the Property. If the second appraisal supports a value of the Property that is more than 5 percent lower than the value of the first appraisal, the lower value must be used as the Property Value in determining the Adjusted Value.

 

 

  1. Obligation to Report to FHA Professional Appraisal Organizations The Appraiser may be a member or hold designations in professional appraisal organizations. If the Appraiser is a member, candidate or associate of an appraisal organization, the Appraiser must report, by calling 1-800-CallFHA or sending an email to answers@hud.gov, any adjudicated actions resulting in a disciplinary action, or the suspension of the Appraiser, to FHA within 14 Days of such action. On disposition or adjudication of the action, the Appraiser must provide FHA with documentation and official Findings. FHA may consider sanctions, including removal of an Appraiser found guilty of professional misconduct as adjudicated by a professional appraisal organization.

 

  1. Superseded Policy: Previous versions of Handbook 4000.1 are amended as described in this Transmittal. All previously superseded or canceled Mortgagee Letters, Housing Notices, and/or Handbooks remain canceled or superseded, except for items notated by an asterisk (*) below. All superseded or canceled policy documents will continue to be available for informational purposes only on HUD’s website. Policy documents that have been superseded in full by the Handbook can always be found on HUD’s Client Information Policy Systems (HUDClips) web pages, accessible from the Single Family Housing Superseded Policy Documents page at http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/sfhsuperseded.

 

 

 

 

Read this Message online: here
 Advertise | Subscribe              Published by OREP                               Oct. 26, 2016   |   Vol. 393
Services Offered this Issue

> Appraisal Institute- Career Building 

> Springhouse AMC

> NAR – Appraisal Opportunities

> Adjustments Online CE (7 Hrs. OREP Education)

> OREP Appraiser E&O Insurance

By proposing the elimination of the Bachelor’s degree requirement, the AQB seems to be listening to the consensus of many rank and file appraisers.
Latest AQB Proposal on College Degree, Experience Requirements

by Isaac Peck, Editor

On September 17, the Appraisers Qualifications Board (AQB) issued its second exposure draft doubling down on its proposed rollback of the Bachelor’s Degree requirement for Certified Residential appraisers. The exposure draft also addresses the experience requirements that are necessary to become an appraiser and achieve the Licensed, Certified, and Certified General credentials.

Amidst talk of a present or impending appraiser shortage, the AQB is taking a clear position that certain aspects of the current Real Property Appraiser Qualification Criteria “may not be necessary to maintain and promote public trust in the appraisal profession.” These proposed changes stand to have far reaching effects on the profession and should be of interest to all appraisers.

Bachelor’s Degree Requirement
Despite earlier indications from the AQB that the Bachelor’s degree requirement is here to stay, the AQB is now proposing the complete elimination of all college coursework for the Licensed Residential credential and the complete elimination of the Bachelor’s degree requirement for the Certified Residential credential. Instead, candidates would now only need an Associate’s degree to become Certified.

In keeping with the first exposure draft in May 2016, the AQB also will offer an alternate path to Certification to those candidates who do not wish to complete an Associate’s degree. With the alternate path, candidates would only need to pass a series of College-Level Examination Program (CLEP) exams covering the following areas: (1) College Algebra, (2) College Composition, (3) College Composition Modular, (4) College Mathematics, (5) Principles of Macroeconomics, (6) Principles of Microeconomics, and (7) Introductory Business Law.

A third alternate in lieu of the Associate’s degree would be for a candidate to complete 21 semester hours of accredited college level coursework in the following subjects: six hours of english composition, six hours of economics or finance, six hours of mathematics (algebra or higher), and three hours of business or real estate law.

By proposing the elimination of the Bachelor’s degree requirement, the AQB seems to be listening to the consensus of many rank and file appraisers. Working RE’s most recent Future of Appraisers survey, in which over 3,800 appraisers participated, indicates that 60% of appraisers who responded are opposed to the bachelor’s degree requirement, with 82% in favor of a path to Certification without a bachelor’s degree.

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Education Instead of Experience?
In its first exposure draft in May 2016, the AQB initially proposed the creation of Practical Applications of Real Estate Appraisal coursework, or Practicum coursework, that could be used to satisfy up to 100% of a would-be appraisers experience requirements when pursuing the Certified Residential credential. The AQB writes that “Respondents were mixed in their support or non-support for this alternative type of experience” and that “many viewed this as non-real world experience and objected to its accounting for the entire experience level.”

The AQB appears to be heeding the warnings of appraisers who are critical of this approach, and based on the feedback of its first draft, is now proposing that the Practicum coursework would be eligible for no more than 50% of a candidate’s total experience requirement.

Even with this proposed change, the AQB acknowledges that further work is needed to develop the standards and course outlines and writes that this important topic will be explored further in a separate, subsequent exposure draft.

Experience Requirements
While the AQB appears to be walking back its earlier proposal of allowing Practicum coursework to account for 100% of a candidate’s appraisal experience, its second exposure draft nonetheless proposes significant changes to the appraiser experience requirements.

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The AQB is proposing revising the experience hours required as follows:
-Licensed Residential: 1,000 hours of experience (no minimum time frame)
-Certified Residential: 1,500 hours of experience (no minimum time frame)
-Certified General: 2,000 hours of experience, with at least 1,000 hours in non-residential appraisal (no minimum time frame)

Such a move would reduce the required hours for each credential by 1,000 hours and remove the minimum timeframe limitation that previously required would-be appraisers to wait 12, 24, or 30 months to achieve a particular credential.

In its rationale for why it finds such changes necessary and timely, the AQB writes that while the experience requirements have not increased since 1998, there have been substantial enhancements in education and examination components of the Criteria that make it appropriate to reduce the experience requirements.

Among such enhancements that the AQB cites as evidence of increased education and examination requirements are: the number of qualifying education hours has increased dramatically; qualifying education now includes case studies and report writing courses; college level education or testing is now required for the Certified credential categories; applicants are now required to pass uniform exams that are increasingly intensive, and there now exist qualification requirements for supervisory appraisers. In other words, because the education, testing, and training systems for qualifying appraisers have improved, the AQB is proposing that the experience requirements can be reduced without sacrificing the quality of the appraiser training process or endangering the public trust.

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The AQB acknowledges that some will resist such a proposal because more substantial experience requirements have been “used by professional appraiser organizations for decades” and that “reducing the number of hours of experience needed for a credential or doing away with the experience requirement altogether,” will be unacceptable to many.

As its reasoning, the AQB writes that its charge is “to maintain and promote public trust in the appraisal profession by establishing the minimum qualifications necessary to obtain a credential” and argues that it is appropriate to consider offering “a more balanced approach to the qualifications needed for a credential by reducing the number of hours of experience required.”

As part of this second draft, the AQB also has decided that it will not allow the use of experience in other professions as a method of qualifying towards a real property appraiser credential. The AQB writes that while some professions may offer valuable experience, “quantifying and reconciling such experience, as it relates to appraising, would be tremendously difficult.”

Timeframe for Changes
Appraisers hoping for quick relief on the bachelor’s degree or experience requirements will need to be patient. The AQB writes that depending on the feedback received and timing of any subsequent exposure drafts, any changes, if adopted, will go into effect no sooner than January 1, 2018.

Send Your Feedback!
Appraisers are encouraged to submit their (concise and considered) comments to the AQB before the November 18, 2016 deadline: Email: aqbcomments@appraisalfoundation.org or mail to: Appraiser Qualifications Board, The Appraisal Foundation, 1155 15th Street, NW, Suite 1111, Washington, DC 20005.

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About the Author
Isaac Peck is the Editor of Working RE magazine and the Director of Marketing at OREP.org, a leading provider of E&O insurance for appraisers, inspectors and other real estate professionals in 49 states. He received his master’s degree in Accounting at San Diego State University. He can be contacted at Isaac@orep.org or (888) 347-5273.
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It’s All Good. How about Lunch?

I started sending out emails originally, because there was something bad happening in the appraisal business every week and I needed a way to vent. I have not really heard of anything too bad happening in quite a while. Hallelujah! That is good because I have been too busy to send out an email. The AMC’s aren’t even looking for the unnecessary 48 hour turnaround times. A 2 week or longer turn time is actually expected by the AMC’s. They don’t even seem to care if you charge a reasonable fee. This has kind of been like the pre AMC era when you could schedule your life to work. It sure is hard to get a day off. I just had 2 days off to get some work at home done.

 

I thought I would ask if anyone is interested in doing an appraiser lunch. It has been quite a while since we had one and the last one was good and we had a good time. I was thinking that if at least 6 people reply to this email saying that they would come to lunch, then we will set one up. If not, then we will wait and see if thing slow down some more. Let me know if you are interested.

 

 

 

Appraiser Board Minutes:

I was checking out some of the minutes for the August meeting of the Appraisal Board and they have a lot of information about AMC regulation in other states and you should check it out at the following link; http://dsps.wi.gov/Documents/Board%20Services/Agenda%20Materials/REA/2016/20160804_REA_Open_Session.pdf. There is some talk about the AMC registration fee, like the email that Bill Druck sent out earlier. They want to charge AMC’s $25-$50 for each appraiser that they used in the prior year. That would get expensive for AMC’s that use a lot of appraisers, especially when it gets as busy as it has been. It might also make AMC’s more loyal to appraisers, if they can save money by using the same appraisers. It might also reduce the number of companies that send out email blasts for the fastest and cheapest appraisers.

 

Here were some of the ones noted and there are many more.

 

Additionally, the Minnesota law eliminates a provision in the state’s appraiser licensing and certification law that had permitted the Minnesota Department of Commerce to charge appraisers the costs of an investigation even if the investigation found no violations on the part of the appraiser.

 

Oregon Appraiser Board Still Wrong on Due Dates, AI Finds An Appraisal Institute review of the minutes from a May 3 meeting of the Enforcement Oversight Committee of the Oregon Appraiser Licensing and Certification Bureau indicates that the ALCB continues to believe — incorrectly — that missing an appraisal due date is an actionable violation of the Oregon appraiser licensing law. The ALCB previously issued an alert to appraisers in Oregon indicating that missing an appraisal due date violated the Uniform Standards of Professional Appraisal Practice. A Q&A released Feb. 10 by the Appraisal Standards Board of The Appraisal Foundation refuted the ALCB belief stating, “Assignment due dates are contractual obligations but are not assignment conditions under USPAP. Turnaround times and similar items are business practice issues and are outside the scope of USPAP.” The ALCB meeting minutes stated, “Although late reports are not a USPAP violation, it might be a statute violation such as negligence or fraud” and continued, “According to legal counsel, the public needs to be protected and [it] won’t be a problem going to a hearing with this problem.”

 

Indiana Court: Appraiser Owes No Duty of Care to Seller The Indiana Court of Appeals ruled May 16 that an appraiser has no duty of care to a seller after he or she appraises a house for much less than the proposed purchase price. The court upheld summary judgment for the appraiser in a case where the seller alleged negligence, fraud and slander of title. The case is BSA Construction LLC v. Jimmie E. Johnson, 49A02-1506-CT-749.

 

Louisiana Enacts AMC Legislation and Rules Louisiana Gov. John Bel Edwards on May 26 signed into law HB 804, legislation that clarifies that appraisal management companies are required to compensate appraisers in accordance with the reasonable and customary fee provisions contained in federal law. The law also gives the Louisiana Real Estate Appraisal Board the authority to collect from AMCs the required National Registry Fees. Also in Louisiana, the state’s Real Estate Appraisers Board on June 20 promulgated several new rules applicable to AMCs, including one that prohibits AMCs from requiring appraisers to sign an indemnification agreement. Additionally, the rules state that the LREAB can take action against an AMC or any person who owns or participates in the business of an AMC if the AMC fails to notify the board within 10 days of any disciplinary action imposed against the AMC, its owners or employees in any state. The rule also requires AMCs to pay appraisers within 30 days after the date on which the appraiser provides the completed report to the AMC. Finally, the rules require appraisers and appraisal firms performing services for AMCs to disclose in the appraisal certification the compensation that was paid to the appraiser or the appraisal firm.

Death of the Summary Appraisal Report and the Elephant in the Room

The Summary Appraisal is Dying

Ever wonder why the ASB took out the summary appraisal report option in 2014? I thought it was a good description of a mortgage appraisal. Perhaps they saw that AMC’s wanted more than a summary appraisal at a summary price and want to keep them happy. I believe that their reasoning was that no one understood what a self contained report was. The new normal in appraisal requirements is a changing thing.

An AMC sent me a list of their top 5 revision requests.

  1. Adjustment Explanations; Please discuss and include data needed to properly explain how all of your adjustments were derived, so the reader of the appraisal can understand. A statement only recognizing that an adjustment has been made is not acceptable,

This pertains to All adjustments, including sales and financing concessions,

-i.e. Are the adjustments derived from paired sales analysis? If so, which sales are the paired sales? If derived from regression, please discuss the data utilized and the results. etc.

2. Be sure to include an explanation of how the value estimate was reconciled,

Which comparables were given most consideration and why,

-Please note, averaging is not acceptable – Per FNMA Selling Guide; “the appraisers’s comments must reflect his or her reconciliation of the adjusted (or indicated) values for the comparable sales and identify why the sales were given the most weight in arriving at the indicated value for the subject property.

These stand out as going beyond what would be in a summary appraisal. Not all AMC’s have this expectation yet, but “Monkey See, Monkey Do”. You know that by the end of the year they are all going to want it because this is something in the Fannie Mae underwriting guidelines and something that has probably always been there. It is awesome to have a well supported appraisal which explains the reasoning to a logical conclusion. Because more work means more pay. Right? I don’t think they will offer a higher fee for the extra work. That amount of work and documentation usually garners 10 times what AMC’s pay. Even if you do the paired sales and regression analysis for every line in the grid, you still have to figure out how to put it in the report so they can see it.

What’s a poor boy to do? Most folks on the internet will say that if you are not getting paid enough for your appraisals, it’s your own fault, because you are not charging enough. That my be more relative to the fact that AMC’s don’t pay enough. If you start sending out well supported appraisals that answer every item in Fannie Mae’s selling guide and you are competing with appraiser Sven who just threw in 3 sales that were the same size and no comments explaining anything for $300 and you are asking for $1,200. Who is going to get the orders?

The easiest solution is to use the tools that are out there utilizing regression and paired sales analysis and the other data crunching programs which give some evidence of how adjustments were arrived at. I sent a list out in a prior email with some of the programs available to Alamode users. Let me know if you have tried any of the ones out there and if they are worth the cost.

AMC’s are a customer service industry. They do not produce anything and their customer service is based on how fast and reliable an appraiser’s estimate of the time to complete an appraisal is and what the cost will be. If the appraiser gets behind, the AMC’s business is compromised. Have any of you ever gotten behind? If you are behind on one appraisal, you are behind on all of the appraisals after that unless you had the foresight to give the AMC’s extended turn times. I think we should also add a fee for the constant badgering that we get from AMC’s, who are really just trying to ensure that their customer service is reliable, and another fee for the endless revisions required after the report is completed so that they can guarantee that the lender will not get a repurchase request.

The lack of a reasonable fee is really the only cause of the demise of the appraisal profession. If fees were reasonable working with AMC’s would be less of a pain in the brain.

DSPS Appraisal Board Meeting on AMC Regulation

It sounds like nothing was decided about AMC regulation at the DSPS meeting. The policy advisor is still researching the topic. Hopefully if they do decide to do AMC regulation it will have items that are good for the appraisal industry. At a minimum it should have a fee study and enforcement of it according to Dodd Frank requirements. The real question in that would be could it also be done for appraisals that have to conform to new normal requirements of an appraisal that would for the most part be a self contained appraisal report.

The Elephant in the Room

If you did not get a copy of the recent appraisal buzz magazine you can read it on line. It talks about the elephant in the room. Customary and reasonable fees and how AMC’s have caused the demise of the appraisal industry.
https://www.appraisalbuzz.com/customary-reasonable-fees-the-elephant-in-the-room/

 

 

There is also a good article on supporting adjustments from OREP at http://www.workingre.com/avoiding-repurchase-demands-part-2/

Dean Smith
Stark Company Realtors
D. Smith Appraisals
Cell Phone: (608) 712-6086
Email: dsmith6341@sbcglobal.net
Blog: http://realestateeinstein.wordpress.com
Website: http://realestateeinstein.com
Stark Commercial lisitngs
Appraisal Website: http://www.dsmithappraisals.com

What is Happening with AMC Regulation in the State

I wanted to give everyone a little update on what happened at the last appraiser lunch with the AMC regulation topic on the table. About 10 people showed up out of the 75 or so people on my email list. Hopefully there are more people than that interested in what will happen with AMC regulation. Debbie Conrad, the appraiser advocate from the realtors association joined us. She is the one that was working with the Wisconsin Coalition of Appraisers and has been attending all of the state appraiser meetings. Since there are so few appraisers in the state, we will need the help of WRA to get good changes into law. Without appraiser input into the topic, we will again be regulated by people who really know nothing about the appraisal process or the issues that have been destroying our profession. According to Debbie, the AMC’s have already sent some lobbyists to the state and one way or another AMC regulation is going to happen. The question of whether or not we need AMC regulation or not may not be an option. Do you want it to be influenced by appraisers or AMC’s?

The WCA had adopted the Appraisal Institutes draft of AMC regulation, which is what Debbie has been working with. The draft is attached to this email thanks to Jim Coutts, who sent me a copy and brought a copy to lunch. The Policy Advisor for the DSPS, Jeffrey Grothman, who is just starting to research the topic to advise the state on how to proceed with legislation, is also using it as a basis for AMC regulation research. I think the federal AMC regulations will also have an influence. Debbie is interested in finding out what appraisers think about the draft and what other things should be in it. We talked about creating a survey to send to appraisers to find out what is important to them. I know everyone is busy right now but I would like everyone to read through the draft and let me know what other things we should try to include in it. Send this email to any other appraisers or legislators that you may know. Your input is important to help shape legislation that will help our appraisal industry thrive. I have also included numerous links below incase some one has more interest in reading about AMC’s and regulation.

I went through it and the following are some items for review that I thought could use more work to help us out they are at the end of the email. Can you think or anything else that needs to be addressed?

 Send me your input for a survey to be sent to all appraisers

A few other things that I would like to be added are:

The elimination of a 48 hour turn around time by AMC’s, which reduces the quality of an appraisal.

Broadcast Emails looking for the cheapest appraiser, which is in search of the least qualified appraiser.

Canned engagement letters longer than 2 pages that are a trap to get an appraiser to do more work than is normal for less pay.

Multiple background checks required by AMC’s.

Unpaid Scope Creep.

Properly training AMC employees with required education similar to USPAP as well as USPAP training if they are not appraisers.

The Real Estate Appraisers Board meeting is scheduled for Thursday May 5th at 9:30 am in room 121A. The following is a list of the board members. If you know any of the members, give them your input. The agenda has not been published, but here may be an opportunity for public comments. Plan to attend. The agenda page link is http://dsps.wi.gov/Boards-Councils/Board-Pages/Real-Estate-Appraisers-Board-Main-Page/

DSPS Real Estate Appraisers Board-Roster

Board Member Office Board Member Type Term Expiration
Nicholson, Larry Chairperson Certified General Appraiser Member 5/1/2018
Clementi, Carl N. Vice Chairperson Licensed Appraiser Member 5/1/2016
Miner, Steven A. Secretary Assessor Member 5/1/2019
Brunner, Scott N/A Public Member 5/1/2016
Coates, Jennifer M. N/A Public Member 5/1/2019
Kneesel, Thomas N/A Certified General Appraiser Member 5/1/2018
Simon, Henry F. N/A Public Member 5/1/2009*
* Board members whose terms have expired may continue to serve until their successor is confirmed by the Senate.

Definitions 2-2, 2-5, The Draft includes definitions of items, which may need more clarification, particularly in reference to the difference between an AMC and an appraisal firm. I know there has been some debate on the difference.

Exemptions to AMC regulations

A6 states that an appraisal management company that is owned or controlled by a financial institution is exempt from state regulation. I think that Lender owned AMC are the worst and should be made to abide by our laws.

Registration B11 requires an “Irrevocable Uniform Consent to Service of Process”. I think that a definition of that may be required.

Appraiser Competency 12

There is a requirement that before assigning an appraisal assignment to an appraiser the AMC has to verify that the appraiser is competent to do the appraisal. Since an appraiser is required to be competent or disclose incompetency under USPAP, it would seem that this requirement may be beyond the AMC’s knowledge and should be worded to say that they will not assign an order to an appraiser who is known to be incompetent without informing the client who has to agree to it. That leaves room for the appraiser to become competent, as per USPAP.

Appraisal Review 13

I think this needs some elaboration on what constitutes a review. I think that if some one is calling for more comparables to bracket items or for any other reason, they should meet the criteria for a review appraiser. If they are doing anything other than checking spelling or names, they should be qualified to analyze an appraisal. It has been my experience that the check box monkeys that are reviewing our appraisals and sending lengthy revision requests from AMC’s rarely have the experience to know a good appraisal when they see one and are not qualified to review our appraisals. Having appraisals reviewed by real appraisers would also help the appraisal industry by providing jobs for appraisers.

Record Keeping 16

I think that each individual record should also be made available, upon request, to the appraiser that completed the report.

Compensation of Appraisers 17

This is the most important part of any appraisal related legislation and there needs to be more information on what constitutes a reasonable fee, otherwise the AMC will just pay what they are used to paying. I think this should also address scope creep with lengthy time consuming revision requests, which many AMC’s tack on after the appraisal is completed and are rarely paid for.

Statement of Fees 18

This section requires the AMC to separate the fee paid to the appraiser and charged by the AMC, when charging the client. It allows the appraiser to show the appraisal fee on the appraisal. This is a good disclosure as it adds transparency to the borrower, who is paying for the appraisal, what exactly they are paying for. I think that the AMC should be required to show their fee with the appraisal they submit, though the lender may not include it, since the new TRID rules did not require the separation on the closing documents.

Surety Bonds 19

This requires the AMC to have a bond that can pay up to 150% of there previous year billings. This sounds sufficient to cover debts to appraisers, when an AMC folds. A little more info on how an appraiser would collect on that debt would be good. You have to collect your money with in 1 year of when the AMC does not pay.

Prohibited Practices 20

1 Says that the AMC may not cause or attempt to cause the results of the performance of an appraisal service to be based on any factor other than the independent judgment of the appraiser. From my experience almost every revision request from an AMC violates this portion and there needs to be a more detailed description of what an AMC can ask for without causing the appraisal service to be based on any factor other than the independent judgment of the appraiser.

5 talks about predetermined valuations including providing comparables before the completion of an appraisal. I think This should also include providing comparables after completion of the appraisal and requesting that sale prices be bracketed, which is a common practice of AMC’s.

18 B does not prohibit an AMC from  charging an appraiser for the cost of discretionary services provided to the appraiser. I don’t know what service an AMC is going to provide an appraiser, but they do want us to pay their technology fees, which we do not need to deliver an appraisal. I think they should be prohibited from charging us to send them an appraisal. They should pay their own costs.

Mandatory Reporting Requirement 21

Requires an AMC to report an appraiser to the board if they think that they may have made a USPAP violation. I do not think that this should be a requirement. It should be at the AMC’s discretion. Our numbers are already limited and everyone makes an occasional mistake or may omit a new USPAP requirement if they have not taken a USPAP class to learn it.

How did AMC’s mess things up?

In 2009 the Home Valuation Code of Conduct and in 2011 the Dodd Frank Act effectively turned over the Appraisal Industry to AMC’s by requiring a firewall between Appraisers and those benefitting from the appraisal product. (The loan officer). It was successful in eliminating most of the pressure from the lender to hit a predetermined value. However, one of the most important provisions in the bill has been ignored for the last 5 years. The requirement for customary and reasonable fees. Because the business model of the AMC was to make a profit without increasing the cost of the appraisal to the consumer in order to compete with the appraiser. In order to accomplish this and make a profit the AMC’s cut the fee paid to the appraiser by as much as 50%. At the same time the AMC’s and lenders began making more and more requirements of the appraiser doubling the amount of work that goes into an appraisal making it harder and harder to make a living as an appraiser. As the years have passed by, the fees have slowly increased and are comparable and possibly higher than they were 6 years ago, but the amount of time and work has now doubled and the cost of living has also increased significantly. The supply and demand relationship between appraisers and lenders has been virtually eliminated by a middle man, which does not contribute to the appraisal service. If AMC’s paid a reasonable fee, working with them would be financially feasible. Some AMC’s are better than others. Some get better and some get worse. There seems to be a constant cry for an increase in what goes into an appraisal and with many, the requirements have made them comparable with a narrative appraisal. The standard 1004 is almost to the level of a condemnation appraisal that general garners a fee of $2,500 to $5,500, but the AMC pays only 10% of that. It seems to be a monkey see, monkey do type of business, and how it looks is as important as what is in it.

The Federal Register Rules and Regulations on AMC Regulation.

Enacted State AMC Laws

State AMC Laws & Regulations

Statutes Regulations
Alabama Alabama
Alaska Alaska
Arizona Arizona
Arkansas Arkansas
California California 
Colorado Colorado
Connecticut Connecticut
Delaware Delaware
District of Columbia District of Columbia
Florida Florida
Georgia Georgia
Hawaii Hawaii
Idaho Idaho
Illinois Illinois
Indiana Indiana
Iowa Iowa
Kansas Kansas
Kentucky Kentucky
Louisiana Louisiana
Maine Maine
Maryland Maryland
Massachusetts Massachusetts
Michigan Michigan
Minnesota Minnesota
Mississippi Mississippi
Missouri Missouri
Montana Montana
Nebraska Nebraska
Nevada Nevada
New Hampshire New Hampshire
New Jersey New Jersey
New Mexico New Mexico
New York New York
North Carolina North Carolina
North Dakota North Dakota
Ohio Ohio
Oklahoma Oklahoma
Oregon Oregon
Pennsylvania Pennsylvania
Rhode Island Rhode Island
South Carolina South Carolina
South Dakota South Dakota
Tennessee Tennessee
Texas Texas
Utah Utah
Vermont Vermont
Virginia Virginia
Washington Washington
West Virginia West Virginia
Wisconsin Wisconsin
Wyoming Wyoming

 

Links to AMC Articles

Housing Wire AMC Articles

News Day Article

Appraisal Buzz Appraiser Surveys

Appraisal Buzz AMC Regulation Articles

Appraisal Buzz Appraisal Management Articles

Working RE AMC articles

Real Estate Appraisers United

The National Real Estate Post

 

First American has acquired Forsythe Appraisals

 

Dean Smith

Cell Phone: (608) 712-6086

Email: dsmith6341@sbcglobal.net

 

Appraisal Website: http://www.dsmithappraisals.com