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USPAP Nazi

I was interviewed on the Appraiser Coach/Dustin Harris Podcast, published July 3.

The topics were: Trainees inspecting, C&R fees, and Celebrity homes.

We  debated on a Facebook discussion of whether or not an appraiser can disclose the owner’s name when appraising celebrity homes. Unfortunately, I did not read the Facebook discussion since it seemed sorta lame (big mistake) and it was removed. The issue is USPAP confidentiality requirements. Dustin said you could not reveal the name and address and I said it was ok and referenced an appraiser’s web page that had the names of all the celebrities whose homes he had appraised in Southern CA.

While discussing it, I mentioned one of my favorite terms, “USPAP Nazi”. I’m sure you know what I mean. USPAP is very gray but some appraisers have very strict interpretations that they make. Do something they don’t agree with and lose your license and/or Go To Jail. No big deal, except when they are teaching USPAP classes and you disagree. But, Very, Very important when they are on state boards.

I taught USPAP for many years, until the Appraisal Foundation mandated what materials and topics had to be used. I loved teaching USPAP and related it to practical, day to day, issues that appraisers have. Not “Do what USPAP says (how I interpret it) or you will lose your license and/or go to jail!

I am sooo glad we have never had a state board in California!! When licensing started, Governor Schwarteneger did not want any additional expenses, including state appraisal boards. Licensed appraisers, that are employees of the state of California, are used for investigations in California. Appraising can be a very small world, particularly in smaller states. Who wants a competitor or personality conflicts affecting decisions on your appraisal license?

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Where to listen to the Podcast #27 – Trainees inspecting, C&R fees, Celebrity Homes with Ann O’Rourke

– Android – http://www.stitcher.com/podcast/the-appraiser-coach
– iTunes – Subscribe to the podcast so you don’t miss any! I am a subscriber.
https://itunes.apple.com/us/podcast/the-appraiser-coach-podcast/id966765322
– Website – http://theappraisercoach.libsyn.com/

Appraisal Today newsletter

Posted in: lender appraisals, USPAP

AMC/lender now accepts trainees signing on appraisal reports

Be sure to check your state’s requirements, as they vary widely among the states.

This is the first one I know of. Maybe they have been reading my free emails where I suggest this is the only solution to the appraiser shortage, now and in the future, that can start immediately. FYI, Red Sky is owned/affilated with U.S. Bank

Excerpts from an email (Appraiser Partner News) sent to appraisers on its panel June 11, 2015

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Supervisory Appraiser Change

Upon review, Red Sky Risk Services, LLC has refined its expectations regarding the involvement of appraiser trainees. Important to note, the following change DOES NOT override specific state statute(s) or appraiser training requirements.

Effective immediately, Red Sky is no longer requiring supervisory appraisers to be physically present with trainee appraisers at all subject property inspections and driving comparable sales.

My comment: There is a short additional list of specific requirements. But, they are nothing new – Supervisor to review report, responsible for report, etc.

 

Appraisal Today newsletter

Posted in: AMCs, appraisal management company, lender appraisals

Are You a Tier 1 or Tier 2 Appraiser?

by Richard Hagar, SRA

Excerpt:

Nordstrom or Walmart? Mercedes or Yugo? Are you a Tier 1 or Tier 2 appraiser? Appraisers have two different business models to choose from.

I have seen that many lenders classify appraisers into two or three different tiers based on their perception of the quality of your product. Which tier are you? The amount of business you have and the amount you are paid is very likely based on how lenders classify you.

There is a lot of appraisal business right now and lenders are begging for high-quality appraisals. Many firms are buried in business, quoting three-plus weeks out in turn time, with high fees; here in the Northwest we are earning $550 for a standard home. If your company is not busy or you are making far less than this, here are some tips.

My comment: Appraiser tiers have been around for a long time. They were used when I started my appraisal business in 1986. In the past, they were referred to as “preferred” or “private banking”, etc. Prior to HVCC they were often used for high dollar properties. After HVCC, lenders placed the appraisal orders directly, not through AMCs they used.

Read the full article. Worth reading!!

http://www.workingre.com/tier-1-tier-2-appraiser/

 

Appraisal Today newsletter

Posted in: AMCs, appraisal management company, lender appraisals

AQB issues Q&A on Background checks, effective 1/1/17

 

Issued June, 2015

Excerpt:

Section VI(C) of the Criteria states:

An applicant shall not be eligible for a real property appraiser credential if, during at least the five(5) year period preceding the date of the application for licensing or certification, the applicant has been convicted of, or plead guilty or nolocontender to a crime that would call into question the applicant’s fitness for licensure.

It is impractical, and likely impossible, to compile a list of every specific circumstance where an applicant must be denied a credential. Section VI(C) is intended to provide states with the ability to deny a credential based on “public trust.” States have latitude to determine, based on their own guidelines, whether or not an applicant falls into this category and should be denied a credential.

My comment: California required background checks on all applicants when licensing first started around 20 years ago. There was a lot of discussion on what disqualified you. I didn’t hear about many license denials for experienced appraisers. I suspect this is because appraisers don’t do much criminal activity (except a few being involved in mortgage fraud). But, some had felonies in the past. For example, a felony for sale of marijuana in the 1960s – many years before the 1990s. For states which have never done background checks it is easier today. They can ask the other states what they did regarding background checks. Every state is different. Check with your state if it will be implementing background checks for the first time.

Link to Q&As

https://appraisalfoundation.sharefile.com/download.aspx?id=s246eb776d104935a#

Exposure Draft, Guide Note 9

https://appraisalfoundation.sharefile.com/download.aspx?id=s79a4e964ae3446db Issued January 17, 2015

 

Appraisal Today newsletter

Posted in: Appraisal Qualifications Board

Appraiser shortage – for AMCs (Appraisal Management Companies), not other clients

Appraiser shortage – for AMCs, not other clients

There is a significant shortage of appraisers willing to work for AMCs with low fees and escalating Scope Creep.

AMCs whose business model is based on low fees to appraisers are having difficulty finding anyone willing to accept their appraisals. They keep calling and calling trying to find someone to work for their low fees.

Direct lenders or the few “good” AMCs are not experiencing an appraiser shortage. Appraisers who work for them turn down AMC work.

 

Appraisal Today newsletter

Posted in: AMCs, appraisal management company, lender appraisals

Comp Photos and MLS, Fannie, USPAP, etc.

Appraisalport polls on comp photos

By Steve Costello, www.appraisalport.com

This month I want to discuss three recent polls dealing with comp photos. In the first poll, we asked “With the availability of MLS photos, do you still feel it is necessary to drive by and photograph every comp?” We had a total of 3819 responses and the top two answers were very close. The winner, with 40 percent of the vote, was “Sometimes, it depends on the complexity of the specific assignment.” Coming in a close second was “Yes, I always want to see any property I use in a report” with 38 percent of the vote. The final answer of “No, I would rather just use MLS photos” only scored about half the votes as the first two answers, finishing with 22 percent. This makes sense because I think most appraisers want to look at a comp before they include it in a report, especially if they aren’t already familiar with the property. I can also see where some appraisers are very familiar with the properties in their area, use many of the same comps over and over again, and don’t feel a need to drive by and photograph them every time they use them.

In the next poll, we asked “In your opinion, with MLS, Google, and other photo sources available to clients, the main reason original comp photos are required from the appraiser is:” This poll had 3986 responses and had a pretty clear winner. A full 63 percent of the appraisers chose the answer “To make sure the appraiser actually drives by the comps.” So it looks like most appraisers don’t think their clients care as much about the actual photo compared to just making sure the appraiser actually visited the comp. The answer we expected to be very popular, “To provide the client with up-to-date photos of the comps – ensuring they exist in the stated condition,” only received 22 percent of the vote. A third response of “So the clients won’t have to take the time to look up the photos from one of the sources noted above” didn’t do well, only pulling in 3 percent of the vote. Not a surprise — we didn’t really expect many appraisers to choose that answer. Finally, 13 percent of appraisers went with “Other reason” as the best choice for this question. We really don’t know if there were one or many “other reasons” or what they are.

Finally, we asked “Would you be in favor of eliminating the requirement to include an original photo of every comp as long as a recent MLS photo of the property could be included with your report?” This question was very popular with 4770 total votes. It also produced a landslide vote with 79 percent of the appraisers selecting the answer “Yes.” Only 15 percent answered “No” and would not want to use an MLS photo instead of an original if it were available. A final 6 percent were “Not sure” how they felt about this issue. So, from this poll it is clear that appraisers feel that an original photo is not a necessity to produce a quality appraisal as long as a good representative photo is available from another source like an MLS.

My comment: As we all know, a photo taken at the time of listing from the MLS is often better than one taken later and USPAP does not  require comp photos. Fannie Mae certifications require that the appraiser inspect the exterior of the comp, not take a photo. What about re-using a comp photo? Why the requirement of an “original” photo? To be sure appraisers drive by the comps.

Appraisal Today newsletter

Posted in: appraisal, comp photos, Fannie, lender appraisals

Housing Forecast: The Present is a Lagging Indicator, and Sometimes it Rhymes

Some Very Interesting comments from Jonathan Miller’s Housing Notes

May 8, 2015

Excerpt:

Earlier this week I came across a brilliant tweet – that when applied in the context of housing, spoke for a lot of the gimmicky click-bait research that comprises a large swath of housing market news coverage.

The present is a lagging indicator.

— Pedro da Costa (@pdacosta) May 3, 2015

 

While I plan to use that quote extensively, my favorite remains one by Mark Twain (supposedly). It is especially useful when making comparisons to the the boom, bubble, bust cycle of the prior decade.

History doesn’t repeat itself, but it does rhyme.

I prefer my adapted version:

History doesn’t repeat itself, but sometimes it rhymes.

So much of what we read or think about housing is backward looking or a provides a current view based on a prior event that had a completely different set of circumstance and worst of all, a lack of context. Sound bites relied on by market participants and media often have limited applicability to specific situations and perspectives.

Link to the full Housing Notes issue:

http://us6.campaign-archive2.com/?u=47540980899c1d755b4cddc48&id=9493fa8875&e=e758e759fb

My comment: I love Jonathan Millers writing, speaking etc. The only appraiser I know who is widely quoted, and interviewed, in the media!!

Appraisal Today newsletter

Posted in: forecast, future

FHA extends deadline for new Handbook 4000.1 to June 15, 2015

Handbook Implementation Date Extended 90-days to Give Lenders More Time to Operationalize

On April 30, 2015, the Federal Housing Administration (FHA) announced that it has extended the effective date for the policies contained within its new Single Family Housing Policy Handbook (SF Handbook; HUD Handbook 4000.1) from June 15, 2015 to September 14, 2015.

FHA recognizes that there currently are a number of competing initiatives occurring simultaneously in the mortgage industry that may be challenging mortgagee and other industry partner resources. For this reason, FHA is extending the SF Handbook effective date by 90 days with the expectation that this additional time will enable mortgagees and others to be fully compliant with the new effective date.

Link to new handbook 4000.1http://portal.hud.gov/hudportal/documents/huddoc?id=40001HSGH.pdf

The bulk of the appraisal section starts on pdf page 441 and runs through pdf page 507.

My comment: We love to procrastinate ;> For appraisers, this means there will be opportunities for webinars and seminars. Also, written explanations. The June issue of the paid Appraisal Today newsletter will have an article on the changes written by Doug Smith, SRA, Montana appraiser. Doug has been writing for the paid newsletter for many years. To subscribe, click on the ad below.

Yes, you can start using the new criteria now. Some people like to get ready ahead of time ;>

Appraisal Today newsletter

Posted in: FHA, lender appraisals

Appraisals-how long to write/how many per week

On average, how long does it take you to complete a 1004 interior inspection appraisal report including inspection time (excluding driving time)?

Another Very Interesting poll from www.appraisalport.com

 My comment: I have been hearing about scope creep causing increased appraisal report writeup times but now there is some data. Significantly increased, and still increasing from pre-AMC days. My non-lender report writing time has not changed from since before HVCC. Appraisalport is a lender portal, so I guess there are some appraisers that write fast and others that write slow. Or, maybe it depends on your clients. AMCs tend to combine requirements of multiple lenders into very long lists of requirements.

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On average, how many “interior inspection” appraisals reported on a 1004 do you normally produce in a week?

My comments: Starting with a conforming tract home close to your office, the time increases, depending on driving time, use of an assistant and client requirements.

Appraisal Today newsletter

Posted in: AMCs, Appraisal fees, Fannie, lender appraisals

It’s Not a Comp, It’s a Sale – Lies, Damn Lies…and FNMA 'statistics'

Another “good one” by Dave Towne, Washington appraiser and commentator

Something’s been gnawing at my craw ever since January when FNMA’s wonderful CU was unleased to the world.  And before that, which still continues, is the AQM process they still use to judge the work of appraisers.

No one else has written about this, or even mentioned it, so I will: It has to do with the word “Comp” which is used liberally by FNMA.

What exactly is a “Comp?”

In FNMA’s world, it’s any property that they obtain, either by their vast AVM process which examines millions of property transactions, or properties that have been extracted from appraisal reports submitted by appraisers……..yes, your work.  In their fuzzy logic, it’s a “Comp” considered for your report if they say it is.  It is not!

A true “Comp” is a property viewed and/or analyzed by a real living, breathing, mirror fogging appraiser who compares that sold property against the subject property in terms of multiple features, characteristics and amenities.  It is not determined by an AVM or algorithm within the vast bowels of FNMA.  Until the property has such analysis done by an appraiser, it is merely a SALE……it is not a “Comp.”

This FNMA lie really became evident to me on 4/20/15 when FNMA released a news release about how CU has been integrated into their on-line Desktop Underwriter software mortgage lenders use, which you can read here:  http://www.fanniemae.com/portal/about-us/media/corporate-news/2015/6239.html?p=Media&s=News+Releases&from=RSS

Within that news release is this quotation from a VP at a mortgage lender:  “The collateral information that CU provides is invaluable and simply staggering,” said Breck Tyler, Executive Vice President, Trustmark Mortgage Services. “CU has aided in providing important comparable data that was previously unavailable or very difficult to get. CU messages in DU will help streamline appraisal review and make the underwriting of an appraisal a much more informed process.”

Then, FNMA released info directed to Correspondent Lenders who intend to use the CU process in UCDP, but don’t intend to sell the loan to FNMA:  https://www.fanniemae.com/content/fact_sheet/collateral-underwriter-non-seller-implementation-guide.pdf

That has this statement:  “Fannie Mae does not instruct or suggest to lenders that they ask appraisers to address all or any of the up to 20 comparables that are provided by CU for most appraisals.”

I want to repeat what I said above…in case you missed the point:  A PROPERTY IS NOT A “COMP” UNLESS YOU DETERMINE IT IS AND INCLUDE IT IN AN APPRAISAL REPORT.  Otherwise it’s just a ‘sale.’

If you’re an appraiser who liberally uses the word “Comp” in place of a ‘property sale’ I would ask that you be more careful.  If you receive info from a lender, AMC or anyone else who asks you to look at the “Comp” they have provided, correct them and use the words “sale property” until you have determined that it truly is a “Comp.”

I’m also asking members of appraisal organizations and associations to communicate your concern about this lie perpetrated by FNMA directly with them, and ask FNMA to change the word “Comp” used in their CU Reports, news releases, instructional materials, etc. to ‘Property Sales’ so that there is no misunderstanding about the significance of this issue.

If organizations and associations won’t do that on behalf of appraisers, then we might as well kiss the profession of residential real property appraising goodbye. Because if a list of ‘sales’ are considered “Comps” then an actual human appraiser won’t be needed to provide supportable property analysis and market value reports.

Dave Towne
dtowne@towneappraisals.com

www.towneappraisals.com
Mount Vernon, WA

My comment: I have been aware of the difference between a sale and a “comp” for a very long time. I try not to mix them up. It is very important when communicating with lenders and real estate agents, who should already know the difference. I am glad that Dave Towne points out this very big difference.

I have not found it to be an issue with non-lender clients, where I use “comparable sales” which is a much clearer term to use, since few are familiar with the term “comp”.

Appraisal Today newsletter

Posted in: Collateral Underwriter, Fannie, lender appraisals
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