Appraisal News and Business Tips

AMCs

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.

 

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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.

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Why have AMCs changed so much since HVCC?

AMCs have been around for a long time. The first AMC, LSI, started in the 1960s. Before HVCC, their market share was an estimated 10-15% of lender residential appraisals. There were relatively few AMCs. Now, there are an estimated over 400-500 AMCs.

I have been writing about AMCs in my paid Appraisal Today newsletter since soon after my first issue in June 1992. In the mid-1990s, when lender business crashed in many areas, some appraisers signed up for AMCs to get work. In those pre-Internet days, often specific forms software and transmission methods were required. Fees were lower than for direct lender work but were stable. There were no broadcast orders, shopping for low fees, or Scope Creep. When business picked up, few appraisers continued to work for them. In my area, there were a few larger appraisal companies who did all the work for specific AMCs.

Then HVCC came and most lenders shifted to AMCs to handle their appraisals. Now AMC market share is estimated at over 80%. Fees varied widely. Residential appraisal fees became sensitive to supply and demand. When business was slow, fees went down. When demand for appraisals is high, such as now, fees went up as many appraisers would not work for low fees. Many appraisers, like other business persons, were afraid to turn down work, even with low fees.

Lenders have always wanted fast turn times, to be more competitive and close their loans. Thus, AMCs push for faster turn times.

When working for direct lenders (and mortgage brokers prior to HVCC) appraisers could establish a reputation for accurate and good quality appraisals with their clients. This is still true today with those clients. However, this is not possible with AMCs who have multiple lender clients and ordering that is not done locally and is done by clerks not appraisers.

The greatest change is in the increasing Scope Creep, which has resulted in longer and longer appraisal reports and replying to many questions about appraisals. Unfortunately, much of the additional information does not affect value or make the appraisals more reliable.

Another significant factor is the widespread use of automated review software, including CU, which means that fewer and fewer licensed appraisers are used for reviews.

Even if you don’t work for AMCs, direct lenders are more “picky” but nothing like AMC requirements. Probably because they only manage appraisals for that lender.

Why has this happened? AMCs work for lenders. Lenders tell the AMCs what they want. I suspect that AMCs with multiple clients combine requests from different lenders into one very long engagement letter/list of requirements.

Everyone I have spoken with, from the lender side, says the recent mortgage crash caused lenders to be more concerned about residential appraisals. The previous crash in the late 1980s, the S&L failures, was caused by commercial property loans. There were some changes made to commercial appraisal requirements, but were minor compared with the changes in residential appraisal requirements post-HVCC.

Mortgage lending is a boom and bust business, starting with Fannie and Freddie in the 1970s. They purchased loans from lenders and made refinancing much easier. When interest rates are low, there are lots of loans. When rates are up, loans decline.

Mortgage lending is also boom and bust regarding risk of defaults. Prior to 2008, since the Great Depression, there had never been property value declines that affected the entire country. Statisticians working for lenders, investors, etc. only looked at their data from the past and did not worry about a national meltdown. So, none predicted it. This is, of course, the minus of using statistical data from the past.

What will happen in the future? We will return to the “typical” days of getting mortgage loans with loosened credit requirements. More and more homeowners will not be “underwater” and will be able to refinance. Will residential appraisal “requirements” loosen? No one knows as we have never had so many requirements that keep increasing. Lenders control the requirements. Until they decide that they are causing too many appraisers to quit, want to speed up their loan approval processes, etc. nothing will change. Residential AMC appraisal fees will continue to be cyclical, depending on supply and demand, similar to commercial appraisal fees as long as AMCs are managing appraisals. The less AMCs pay to appraisers, the higher their profits. Maybe lenders will step in and tell AMCs what they must pay their appraisers.

What about direct lenders? There is some scope creep, but not much as compared with AMCs. They don’t shop for the lowest fee. My advice to appraisers is to work for direct lenders whenever possible. Many appraisers with over 20 years of experience still get most of their work from them. When business is slow, they accept AMC work. Another option is to work for AMCs that work for one, or a few, lenders. Then the requirements will not be from a lot of different lenders.

NOW IS THE VERY BEST TIME TO LOOK FOR NEW NON-AMC CLIENTS. WHEN EVERYONE IS BUSY AND TURNING DOWN WORK!! I HAVE SPECIAL REPORTS, LOTS OF MARKETING TIPS FOR NON-AMC LENDER WORK AND ARTICLES ON NON-LENDER WORK IN MY PAID APPRAISAL TODAY NEWSLETTER. www.appaisaltoday.com

 

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Collateral Underwriter and price per sq.ft. adjustments

Fannie is using this to show that appraisers have been using adjustments that are too low, resulting in less reliable values. They are often low “legacy” adjustments. Also, GLA adjustment is one of the few factors that work well in regression.

I suggest using replacement cost new less depreciation. For replacement cost you can use local builders or cost service such as Marshall & Swift, whichever is more accurate in you area. Then take off depreciation. The result is depreciated cost. Divide by GLA. The result is depreciated cost per sq.ft.

Fannie uses price divided by sq.ft. which does not consider land value or depreciation, information which Fannie does not have available.

For example, builders cost on a property is $100 per sq.ft. Your estimated physical depreciation is 30%. Obviously, $25 per sq.ft. adjustment is not correct. There may be functional or external depreciation, which you can include. Be sure to include how you determined your GLA adjustment in your appraisal.

Market based GLA adjustments are better, such as matched paired sales but the method above will work as a guideline.

Why are adjustments low? To comply with the 15/25% adjustment guideline, which Fannie has removed. It was never a requirement. Fannie has never had a 10% per line adjustment guideline. Of course lenders and AMCs can still require the use of the 15/25% adjustment which could be a big problem for appraisers which can result in less reliable values. I never considered the 15/25 guideline in any of my appraisals, but I never worked for lenders or AMCs who required that appraisals conform to it.

Check out the graphs on GLA and 15%/25% adjustments in the FAQ document below. I included 4 of them in this month’s paid Appraisal Today newsletter.

Get the facts about what Fannie is saying, not just rumor and speculation. Subscribe to the paid Appraisal Today!!

https://www.fanniemae.com/content/announcement/ll1502.pdf

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Collateral Underwriter warning messages and Every Increasing Scope Creep from all sources

My latest opinions and observations, as of today

Fannie does not want appraisers to receive warning messages unless a “human” has reviewed the appraisal report. They want to reassure real estate agents mostly that appraisals will not be delayed. Of course, I have no idea how many underwriters have the time to read the 30+ page report. Maybe they can search the report for what they are looking. I am sure this is/will be slowing down loans.

But, I keep thinking that even if appraisers received a few CU warning messages, it is a small, small percent of all the stips from all the review software that AMCs use. No one seems to notice that appraisals take longer the more stips that appraisers receive. Particularly, when all the stips are not sent at the same time. No one seems to notice this, or care about it, except appraisers!!

These non-CU stips are mostly from arbitrary “rules” which CU does not use. Such as: picky UAD stips, “add 2 more comps”, or please review the list of “comps” from the real estate agent or borrower. Some are still using the 15%/25% adjustment rule.

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Appraisal adjustments "The Dirty Little Secret"

A Few CU Factoids
– Not all loans go to Fannie – VA, FHA, jumbo, etc.
– Fannie guidelines, including CU, are the minimum. Lenders can add their own, even keeping 15-25% adjustments.
– Lenders are not required to use CU.
– CU sends out appraisal warning messages for adjustments on: GLA, lot size, view, condition, quality, and location. For now.
– Gradual implementation of CU’s web based interface, which has the infamous “20 comps”, mapping, etc. Not available to AMCs.
A few CU comments and opinions from me:
I need a Book of Adjustments!!! Maybe a few of Fannie’s will “leak” – wiki leaks ;>
– AMCs are now asking for adjustment support from non-CU adjustments. More Scope Creep??
– Mass confusion on what gets sent from underwriter to AMC to appraiser – warnings, Risk Scores, etc.
– The recent Fannie Letter to Lenders about CU said that the intent is not to overwhelm appraisers with warning messages. But, are underwriters going to read (and understand) 30+ page appraisals? I’m glad I’m not an underwriter!!
– How to respond to warning messages – not clear.
– Requests from AMCs include CU and non-CU requests. Sometimes hard to tell where they are from.
Adjustments – the “Dirty Little Secret” of Fannie Form Appraisal Reports
I can’t think of any time a client asked me for my support on an adjustment prior to CU. They have been accepting the usual responses, which are in many boilerplates: Based on my many years… or matched paired sales… etc.

A critical issue to me is that the dollar adjustments seem to indicate that residential appraisal values are precise and very accurate, which is not correct. There are lots of factors affecting home sales as compared with income property such as apartments and commercial property.

I have asked many very experienced appraisers how they “support” adjustments. Most use “rules of thumb”, such as using a percent of price per sq.ft. for GLA. But, this number includes land. Or, they use adjustments they were given when they were new appraisers. Of course, if you only appraise conforming homes in conforming tracts built in the past 10 years, it is much, much easier.
For now, CU only sends out warning messages for these adjustments: GLA, lot size, view, condition, quality, and location. This is a very small percent of all the UAD coded data. Plus, some data is not UAD coded, such as pools. But, many state regulators expect to see support for all adjustments in your work files.
We all need a Book of Adjustments ;>
Of course, all of us have adjustments that we have accumulated over the years, or recently developed. But, with CU we are being compared to peer and model adjustments. Of course, no one tells us who or what they are. Sometimes appraisers are given this information.
Regression to support adjustments
Regression will not work for all adjustments. It works well in conforming tracts less than 10 years old. After that, it goes downhill. This has been shown many times for AVMs. I really wish I could just buy regression software and have it calculate them all for me!!
Using qualitative adjustments
I did my first SFR appraisals this week without not making any dollar adjustments when I use form reports for non-lending work. I did make time adjustments (which are very easy to support) as the effective date was June, 2014, when prices were increasing rapidly in my market.
I used plus and minus signs in the grid. I use the 2005 Fannie forms but do not use the Fannie certification or limiting conditions. I use my own.
For awhile in the late 80s or early 90s Fannie had a form with pluses and minuses, so I had some experience. Also I don’t use dollar adjustments in my 5+ unit apartments or commercial appraisals.

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CU warning messages – grrrr

A few appraisers are reporting getting CU appraisal warning messages from AMCs. Some AMCs get the messages and and some don’t, depending on the agreement with their lender client.

I sorta believed all the “experts” who said CU would not affect appraisers much, except the many us who do not have market based adjustment support in our work files (which we should have always had). “They” said appraisers’ time for responding to AMC questions will not change. Fannie’s reviewers have been using CU for about two years. Some lenders beta tested it. They all liked it. But, I wonder if it was tested with “boots on the ground” appraisers who actually had to respond to the warnings??

In January I wrote up a long CU article for my paid Appraisal Today newsletter. In the February issue I will have another long article, focusing on the differences between the old and new CU warning messages. They are very different. AMCs with access to lender’s warning messages are sending them to appraisers, such as:

Old message (pre-CU): Condition adjustment for comparable property #<comparable number> appears excessive.
New message(CU): The condition adjustment [for comp #X] is smaller than peer and model adjustments
New (CU): The condition adjustment [for comp #X] is larger than peer and model adjustments.

There are other messages about condition ratings different that peers and model.

I don’t know how our “peers” and The Model made their adjustments or ratings and what they are. I don’t know how to respond as to why mine differ.

Now that appraisers are getting the warnings, they are asking how to respond to them. Who are these peers? What is the model? I have no idea how to respond, except to say “I don’t know who the peers are and how they determined condition or what method they used for their adjustment. I am unable to respond.” How do you know what the condition is really like for comps? There are lots of ways to estimate an adjustment for condition. You can explain what you did. But, who is right? You, peers, or model?

MLS is soo reliable (Not) for estimating comp condition. I don’t think they will like “matched paired sales” on all of your responses for the method you used for adjustments.

Looks like maybe there will have to be some webinars for appraisers, not just underwriters, explaining how to respond.

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Appraisers not getting access to their own data on CU

There is a petition and a letter being circulated about appraisers getting access to CU, particularly the Web interface which lists comps. This is unlikely for many reasons, which I write about in my paid newsletter.

More important (and more likely to occur) is: Why don’t appraisers get access to subject and comp physical characteristics from the CU database, which was provided by appraisers using UAD?

For example, which appraisers are able to measure their comp GLAs? Not many. This data would really help appraisers do better appraisals. We can always look at MLS interior photos and interview agents, buyers, and sellers for other information we need, such as condition. When the MLS listing says “contractor special” or “fixer” that is a good indicator of condition.

The only reason I have heard is that appraisers vary widely and there are too many differences. GLA is a good example. This has has always varied among appraisers. When I used the old CMDC appraiser database in the late 1980s, sometimes there were more than one source of GLA on a property. I have done relocation appraisals since 1986. It was very seldom that the 2 or 3 appraisers have the same GLA. The “rule of thumb” was up to a 5% difference in GLA was ok.

How many appraisers are “fudging” their dimensions to make their GLA match public records and avoid “stips”? Hopefully, CU will change this. Maybe CU will notice how many appraisers just use public records and how many use their own measurements.

I am really hoping that Fannie allows appraisers to get property characteristic information. It will help all of us – Fannie, lenders, AMCs, appraisers, reviewers, etc.

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CU – census tracts, adjustments, "bad apples", etc.

There is a lot of misinformation about CU. No one knows what will happen when CU is fully implemented. I speculate myself. I am an appraiser. I have opinions ;>

UAD is mechanical. CU is asking appraisers to think about their appraisals, not how to classify a characteristic.

For the appraisal profession, I think CU will make us better appraisers by making us take a critical look at adjustments. It will also help get rid of the “bad apples”, including appraisers that “push” values, throw anything into the form to get it out the door, need lots more training and education, etc.

I think Fannie’s main purpose of CU may be to stop appraisers from having low (or high) adjustments, inappropriate comps, using Q/C ratings, etc. to make values higher. That is what they worry about.

Only using comps from within the subject’s census tract is ridiculous and I’m sure CU will not be doing this. It is a good idea to see which census tracts match the neighborhood boundaries that you use. Or, part of Census Tracts. Then you can put the census tracts you use in your appraisal. In some areas census tracts are way out of date due to new construction, plus other problems.

To find census tracts near any property, go to http://www.huduser.org/qct/qctmap.html and type in an address.

I started my business in 1986 and had to put census tract numbers in my appraisals for the first time. I had previously worked for an assessor’s office and had never done a lender appraisal. I used Thomas Brothers Census Tract books to find them. To me, they often represented a reasonable way to delineate all, or part of, a neighborhood. Looking at the current census map for Alameda, CA, my city (population 75,000), it definitely did a good job of defining neighborhoods. However, I usually have to include more than one census tract as there is not enough data to do an appraisal otherwise. It did miss one very important neighborhood where most of Alameda’s large historic homes are located. There is a significant premium for being in this neighborhood. I very, very seldom go out of this neighborhood for comps. I suspect there are issues like this in other geographic areas. I have no idea what area Fannie would use, so I would put an explanation in my appraisal.

The problem is the forms, which were developed for use on tract homes. If you are not appraising a conforming tract home, it is like trying to put square boxes into round holes.

Every appraisal will have a risk score. A high risk score (1.0 to 5.0, where 5.0 is high risk) does not mean an appraisal is “bad”. It may be in an area of declining values or have a negative location problem. Or, not enough comps to provide a reliable value.

Remember that only certain UAD items will be considered by CU for now. If it is not UAD formatted, it will not be looked at. I don’t think Fannie’ use of census tracts will be the issue.

The Big Issue is support for adjustments. I have no idea how to support all the adjustments I make in my appraisals. I know what buyers will pay more, or less, for. But, I don’t know the exact dollar amount.

Regression is just one way to support adjustments, but it will not work for many adjustments, particularly if there are very few sales. Regression is not the only answer. There are many other methods. I will be writing about them in my paid email newsletters.

Regression works very well for time adjustments. Be sure yours are market based, not just from an MC form.

I am seriously considering not making any dollar adjustments when I use form reports for non-lending work, except time adjustments. I never make dollar adjustments on narratives and apartment form reports. My state regulator wants to see support in my files for adjustments.

Just because there is a box does not mean it has to be filled in. Qualitative adjustments are fine. There was a Fannie form developed and used for awhile in the 80s or early 90s that did not use dollar adjustments, only plus or minus signs. I worry about that a lot. The old Fannie 2-4 unit form did not have any adjustment boxes. I really hated when they changed that form to include adjustment boxes and de-emphasize the Income Approach.

No one knows how CU will work out. Will everyone turn down appraisals except for conforming tract homes? Will there be no one to do the tough appraisals and work in rural areas. When appraisers are compared, does the majority opinion win?

Will the days of 24 hour turn times and $200 fees be gone? Will AMCs stop broadcasting all appraisal orders to everyone on their fee panels? Will all appraisers be seen as the same and interchangeable? Or, will appraisers be rated on skills, education and experience? Will fees go up? Will fees be based on difficulty of the appraisal? Will lots of appraisers abandon the lender appraisal ship of fools?

Read the webinar pdfs and look at the maps from the two Fannie Webinars to see what they actually are doing. I spent lots of hours doing this, plus speaking with others about what they thought. Of course, it was for a 12-page article in my paid newsletter. Plus 18 pages of excerpts from Fannie documents and webinars. I probably would not have done it otherwise ;>

Go to www.fanniemae.com/singlefamily/collateral-underwriter and listen to Fannie’s two webinars for underwriters – very good with excellent illustrations and explanations. Plus, read the FAQs. You need to register, but it is very easy and you go directly to the webinar and can return at any time. There are lots of links on the web page for more information.

Last month’s January 2015 issue of the paid Appraisal Today newsletter had a 12-page article on CU plus 18 pages of addenda material. The February and subsequent issues will address problems such as how to make adjustments. Click the ad below for more information.

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How much time should clients give appraisers to deliver a 1004 report on a typical (not unique) property?

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