Bracketing – lenders gone wild!!

Filling up an appraisal report with “comps” that “support” adjustments is a hassle for appraisers and often does not contribute to the accuracy and reliability of the subject’s value. Note that the “comps” are sales, but not necessarily comparable sales.

Sure, it often works fine when you are appraising a typical home in a conforming tract with few adjustments. But, what if you work where I do, where most homes were built prior to 1930 and many Victorians were modified over the years? I am hearing about appraisers being asked to use sales from 2-8 years ago for “bracketing”. What if you have an “oddball” home in a conforming tract, such as a home with a large addition or an “inlaw” space?

One of my first appraisal clients was a local lender who still has an appraisal department, is very savvy and treats their fee appraisers as professionals. They specialize in Fannie Mae loans. I recently spoke with an appraiser who does appraisals for them. She said they were asking for “bracketing”, including asking their appraisers to consider using very old sales if necessary.

Why are lenders asking for “bracketing” of adjustments? The same reason we have been hearing since 2008. They don’t want Fannie to require buybacks of the loans they sold to Fannie. They are also worried that Fannie will not buy a loan. I have noticed that lenders are often like sheep. When one does it, or says it should be done, they all do it.

Perhaps they are doing this in order to have some sort of “support” for adjustments. I guess they finally figured out that putting “adjustments done using matched paired sales” in an appraisal doesn’t mean much.

More important, state regulators want to see “support” for adjustments. I don’t know how to “support” all the adjustments in many of my appraisals. I know what buyers will pay more or less for. But, the exact dollar amount can be very difficult to determine. I don’t think it is right to conclude an incorrect value just because I cannot prove the exact dollar amount. Matched paired sales and statistical analysis doesn’t work for many adjustments. Matched paired sales can be manipulated and statistical analysis often does not work due to lack of data.

Market conditions is the easiest adjustment. Square footage and number of bedrooms, lot size, can often be supported statistically. If I spent many, many hours I might be able to “support” some of the other adjustments. But, would my appraisal be more accurate? Does my scope of work agreement with my client include spending 2 weeks or much more on a home appraisal for a loan?

Appraisers should consider what affects value. I worry about appraisers not making adjustments that are indicated by the market because “support” can be very difficult resulting in a less reliable, or inaccurate, value.

I have been thinking about not using any adjustments in my non-lender residential appraisals. Instead I could just use plus or minus signs. Why? I can’t “prove” most of the adjustments for my state regulator. I worry about losing my appraisal license. My clients don’t care about dollar adjustments.

What’s the answer? The only answer I can think of is to carefully pre-screen appraisal requests so you only accept appraisals of conforming homes in conforming tracts.

Should you do bracketing when the sales you use are not comparable? Some appraisers refuse and others do it. In my business, when requested to include information that is not relevant to the value, I always put “Included at client request. Given no weight.” Only you can decide what works best for you.

I am writing an article for the August issue of the paid Appraisal Today about making more money increasing your hourly billing rate. Working in conforming tracts is Number 2 of my primary suggestions.

To subscribe, and increase your hourly billing rate, click on the ad below!!

Appraisal Today newsletter

Low appraisal fees

Appraisal Fee vs. the Cost of Gas

Excerpt:

Two decades ago, gas cost about a dollar per gallon.  Let’s face it – almost everything (milk, eggs, etc.) was cheaper, including obtaining and maintaining your appraisal license. But surprisingly, one thing that has pretty much stayed the same is the amount you charge for an appraisal. In 1994, the average appraisal fee for a residential property was $320. Today, the average appraisal fee is $350. This is a 9% increase over 20 years, far below the rate of inflation.  In inflationary terms, this means we are currently being paid less than we were 20 years ago.

Let’s compare the average appraisal fee to the cost of gas during the last 20 years. … Gas has increased 239% over 20 years while the amount appraisers collect on average over the last 20 years has increased only 9.375%. This is a pretty scary picture for appraisers.  After factoring in the AMC percentage (25-50%) and our overall higher operating costs, it’s amazing that any of us can survive in this business.

My comment: Interesting analysis. I have been setting my residential non-lender fees based on what borrowers are paying for loan appraisals. I am still slightly under those fees. But, if prospective clients call around, some appraisers are charging much lower fees, even close to typical AMC fees. Why? The same reason many appraisers have always worked for low fees, even prior to hvcc. Fear and Greed. Afraid they will never get another assignment (Fear) and don’t want to turn down any assignments (Greed). This applies to all types of businesses, not just appraising. Remember the Primary Rule of Business – There is Always Someone Cheaper. Sometimes competing on price works out, such as Walmart. But, for most businesses it is a death sprial to the bottom.

Click here to see the graph, read the full commentary and comments, and post your own comments!!
http://www.frea.com/blog/appraisal-fee-vs-cost-gas

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Why You’re Not Charging Enough For Your Work, And How To Change That
Source: Forbes magazine. It’s not just appraisers!!!

Excerpts:

“If you’re making $50,000 or less in your business, it’s not a business, it’s a job, and it’s not a good job either.” … If you were working for someone else, and had to toil for 18 hours a day to make ends meet and still generated less than $50,000, you’d say something would have to change, right?”

4.  Develop stronger boundaries. Start saying “no” to outlandish requests for your time and effort.  Know what your time is worth, and demand respect for that.

6.  Charge 20% more starting today. Just do it.  Then figure out what the right number is within the next few months, and start charging it. You can transition your existing clients to your higher fees in a more gradual way, but new customers and clients need to pay you more, starting now.

Worth reading. Thanks to appraiser John Carlson for posting this most interesting link!!
http://www.forbes.com/sites/kathycaprino/2014/06/28/why-youre-not-charging-enough-for-your-work-and-how-to-change-that/

Video – AMCs – fees, blacklists, etc.

http://www.youtube.com/watch?v=QPQjJidp8b0

The topics include:
– Major restructuring of residential lender fees since HVCC
– AMC fees and how to make more money
– Consolidation and what it means for appraisers
– What is an AMC
– AMCs since 1969, when LSI started
Note: the fee discussions start at about 14 minutes

I have been writing about AMCs since 1992 in my paid Appraisal Today newsletter. My speaking style is much more informal than my writing style ;>

Phil Crawford, the host, is a certified general appraiser who has been appraising (residential and commercial) for over 15 years. He is a third generation appraiser. He has been doing interviews on a local Cincinnati real estate radio show for a few years. We are a good match!!

To see other radio shows, go to www.voiceofappraisal.com

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My first interview was in April, on Fannie Mae’s exclusionary list. To listen to this interview, and listen to the other shows, go to www.voiceofappraisal.com and scroll down the page to the video “E3: The Fannie Mae List!!”

Topics included:
– Why Fannie is using UAD data
– Fannie and Big Data
– How appraisers get on the black list
– Which appraisers are getting on the black list
– The future of Fannie’s Big Data

How accurate is the reported square footage from the tax records in your primary service area?

To keep up on what is happening in appraisal businesses, mortgage lending, USPAP, etc. , Plus humor and strange homes, sign up for my FREE weekly appraisal email newsletter, sent since June 1994. Go to Home on the left side of the menu at the top of this page or go to www.appraisaltoday.com
Sign up in the Big Yellow Boxes

I regularly write about hot topics in appraising and appraisal business management issues
in my paid Appraisal Today monthly newsletter.
$99 per year or (credit card only) $8.25 per month, $24.75 per quarter, or $89 per year.
For more info, go to https://www.appraisaltoday.com/products

How accurate is the reported square footage from the tax records in your primary service area?

3/10/14 poll – www.appraisalport.com
Poll Results
– Very accurate for most homes 869 votes – 16%
– Mostly accurate (about 75% of the time) 2495 votes – 55%
– Hit and miss (about 50% of the time). 1470 votes – 27%
– Not reliable (accurate less than 25% of the time). 475 votes – 9%
– The tax records do not usually show the square footage in my area. 127 votes – 2%
Total votes = 5,346
My comment: AMCs seem to be assuming that tax records are more reliable than appraisers’ measurements. WRONG!! I started appraising at an assessor’s office in 1975. We were no more accurate than any other appraisers and never thought that our square footages were exact.
I used to do a lot of relocation appraisals where 2 or 3 appraisers were hired to appraise the same property. Very, very seldom did the appraisers have the same square footage.
A few years ago, a local real estate agent asked me about an appraisal where the sketch did not match the house. Tax records sq.ft. was way off. The appraiser had “fudged” the dimensions to match public records.
Do many appraisers do this to avoid AMC hassles or they were taught to do this by their supervisors?
I have always looked at tax records sq.ft. as a cross-check, but never assumed it was more accurate than my measured sq.ft. In some neighborhoods and cities, they are accurate and are very unreliable in other areas as they often are not correct.
9/20 update. Not much has changed. Still a big problem!!

Appraisal Today newsletter

Generally speaking, how accurate do you find MLS data in your area?(Opens in a new browser tab)

10 reasons why public records and the appraiser’s square footage can differ(Opens in a new browser tab)

12-27-18 Newz:// Change Your Templates!!/Corelogic takeover?/Square footage?(Opens in a new browser tab)

6-7-18 Newz//Square footage, Novelty Architecture, Appraisal Fraud(Opens in a new browser tab)

AMC fees – going down?

Poll Results – www.appraisalport.com  survey 11/4/13

Have you noticed any change in the fees being paid by AMC’s since the market has slowed?

– No, fees seem about the same as before. 2,618 votes 52%
– Yes, the fees seem to have increased slightly. 464 votes 9%
– Yes, the fees seem to have decreased slightly. 1,419 votes 28%
– Not sure 488 votes 9%
Total Votes: 4,989

My comment: I am forecasting declining AMCs fees because loans have dropped. Keep up with fee changes at www.appraisaladvisor.com  which is now free to all appraisers!!
I have lots of tips on getting higher AMCs in my AMC Special Report – $20 and FREE to paid subscribers!!
go to www.appraisalport.com to take the current survey.

Appraisal Today newsletter

StreetLinks AMC's new AppraiserPlus Program-paid on inspection, no micromanagement?

My comment: Hmmm… we will see what happens. Maybe too many appraisers took Streetlinks off their approved AMC list?

Full Streetlinks press release:

May 23, 2013 /PRNewswire/ — StreetLinks Lender Solutions(R) announced today the August 2013 launch of its AppraiserPlus(SM) program. AppraiserPlus(SM) significantly enhances the professional partnership between StreetLinks and appraisers by removing the traditional hurdles of micromanagement and post-completion appraiser payment cycles. StreetLinks’ lender partners will continue to benefit from exemplary quality and service levels, with the assurance that they will never be responsible for an AMC’s failure to pay the appraiser.

“I have said many times that we want to make a positive impact on our industry and to continuously make it better than it was when we entered. AppraiserPlus(SM) is consistent with that goal by providing measurable benefits to appraisers and lenders through real partnerships — not traditional vendor micromanagement,” said StreetLinks President, Tom Hurst. “This program allows appraisers to focus on running their businesses and brings back the days of “COD” style payment. This announcement is a year in the making and as an original founder of StreetLinks, this is the most exciting announcement of my career.”

For years, traditional AMCs have put all appraisers into a single bucket and micromanaged every aspect of the process, resulting in real or perceived nuisance calls, texts and emails that interfere with the appraiser’s productivity. While StreetLinks has never set appraisers’ fees and has remained loyal to exceptional appraisers, the company also approached each order with a standardized follow-up process. AppraiserPlus(SM) changes that trend by restoring the days when appraisers were trusted to run their businesses and provide great service and quality reports, in addition to receiving the majority of their payments at the inspection versus weeks or months later.

AppraiserPlus(SM) will limit or remove calls, text messages and emails to participating appraisers during the appraisal fulfillment process, thus allowing appraisers to spend their time inspecting properties, compiling data and writing appraisal reports. Appraisers will have the opportunity to remove nearly all follow-up questions, revisions and stipulations by completing a StreetLinks QX review prior to report delivery. Additionally, AppraiserPlus(SM) will generate ACH payments to appraisers the same day the property is inspected.

Appraisers accepted into the program agree to consistent and fair service metrics and quality control requirements. Hurst noted that this will also ensure lenders that the best, most qualified appraiser will be handling each report.

“We have spent years developing great partnerships with our clients and continue to see unprecedented growth and capture market share. This program will strengthen our partnerships with appraisers while driving additional value for our clients,” Hurst added. “With multiple AMCs recently closing their doors, some lenders have been put in a tough spot — including being left to pay millions in situations where the AMC collected the funds, but failed to pay the appraiser. AppraiserPlus(SM) mitigates such risk, making it a win for both appraisers and lenders.”

About StreetLinks

StreetLinks Lender Solutions provides innovative and comprehensive suite of valuation services and lending technology solutions to banks, lenders and other mortgage industry firms. StreetLinks’ commitment to quality and service, embodied by our partnership approach to clients and appraisers, continues to set us apart as the nation’s premier lending solutions partner. Our products and services are used by thousands of mortgage bankers and appraisers nationwide to simplify and improve everyday business operations. For more information, visit www.streetlinks.com/landing/AppraiserPlus.

Contact Information:

Tom Hurst

tom.hurst@streetlinks.com

317-215-8182

Link to streetlinks web site:
https://www.streetlinks.com/landing/AppraiserPlus

Appraisal Today newsletter

The First Rule of Real Estate is location, location, location. But, do lenders care?

Not every property fits well on residential forms. Today, many don’t fit due to the incredible scope creep.

Savvy appraisers are screening appraisal requests and turning down any assignment that will cause “problems” when submitted. Many appraisers are very busy. Every minute spend on a tough appraisal is time that could be spent on appraisal that takes much less time, not counting all the stips. The time to take the “tough ones” is when business is slow. If an AMC doesn’t like it when you turn down assignments, drop them and get a new AMC to work for. There are plenty of them desperate for appraisers.

Lender appraisal commoditization, and the UAD, have significantly decreased the focus on the importance of what appraisers provide – expertise in a local market. Every market, and submarket, is different and unique. In many areas, the markets are changing on almost a daily basis.

More and more frequently, appraisers are not trusted and local experts. The incessant requests to “consider” comps from public records, change the “wording” of a phrase, appraiser vs. public records sq.ft., cats in photos, etc. Do they even care about local knowledge? Is it just fitting everything into a form that can be easily “reviewed” by software and unlicensed persons that focus too often on what is irrelevant to the value opinion? Is this information what clients (lenders and investors) really want?

More important, the wide use of non-local reviewers with no local knowledge really makes it hard to explain what is happening so it fits into their rigid criteria.

For example, in some markets location on a busy street is not a factor that affects market value and in others it has a significant affect on value. Or, location on the first floor in a condo project is a plus, and in others it is a minus, for various reasons.

Don’t let lender restrictions affect your value or what you put into your report!!

Appraisal Today newsletter

New AMC – 8 hour turn time!!

An AMC to Keep Pace With?
Q&A with Richard Johnson of Pacer AMC
April 1, 2013
Appraisal Buzz

BUZZ: How will you differentiate your company from the other 500 AMCs?

RICHARD: We have created a unique appraiser scorecard. We have an algorithm that measures the appraiser’s self esteem. We find appraisers who set a low fee, never complain when we are a slow pay, and love challenging assignments. We have no dress code. Appraisers just hate that.

We have spent a lot of time picking the best appraisers for our assignments. We call it dialing for dollars. We reward our processers based upon setting new lows.

Because we are the low cost provider we attract the very largest lenders in the US.. These large lenders too have an algorithm that includes input as to the cost of regulation. They have figured out the risk of penalties and fines is somewhere between slim and none. They have lobbyists to ensure that. We have hitched our star to their wagon.

BUZZ: What is this we have heard of your 8 hour Turn Times?

RICHARD: One of the ways we feel we can stay ahead of our competition is we have instituted an 8 hour turn time. We feel it shouldn’t be too hard to get all our appraisals done the same day they are assigned.

Of course we are not unreasonable though if a property is over 250 miles away we allow an extra 2 hours to submit your report.

BUZZ: With all the transparency, disclosures and Customary & Reasonable laws how do you get away with being the low cost provider?

RICHARD: It is really simple. We know our clients love AMCs because they get our services for free. It is the greatest business on the planet. The appraiser pays for the services for the lender. What a racket. We find appraisers who are willing to drive anywhere and do anything for an ungodly low fee.

We don’t worry about compliance because the appraiser signs an affidavit that certifies we have paid them a customary and reasonable fee. Have you seen the CFPB enforce any appraisal rules ? No of course not. Zero risk for lenders and AMCs.

My comment: be sure to click on the link and read the rest of the articled before you let your blood pressure go way up ;> It was published on April Fools Day!!

http://appraisalbuzz.com/an-amc-to-keep-pace-with

Appraisal Today newsletter

AMC Declares Bankruptcy: What Appraisers Need To Know About Bankruptcy

By Ramir Rodriguez

You received a letter in the mail informing you that your client has filed for .  It is this moment you realize that this bad news just became your problem.

Many of us are familiar with the recent bankruptcy filings of and its  bankruptcysubsidiary .  Peter Christensen, attorney and general counsel to LIA Administrators & Insurance Services, shared in his blog that the total unpaid fees to , agents, and brokers as listed in bankruptcy documents is $11,048,411.97!  This is a remarkable amount.  Evaluation Solutions’ bankruptcy documents accounted for $9,349,612.97 of the total amount and a separate filing of its subsidiary was for $1,698,799.

I Received A Notice… Now What?

If you received a notice regarding Evaluation Solutions/ES ’ (I will refer to them as ES) bankruptcy you may be wondering what the next step is to try and recover money owed to you.  Yes, a client’s bankruptcy can be costly for you, but most importantly, not adhering to the rules of the bankruptcy process can cost you significantly more.

Knowing the types of bankruptcy, how to play by the rules, and what you can (or can’t do) will help you understand the scope of your problem and ensure you don’t get in trouble.

Types of Bankruptcy

There are lots of information you can gather from the bankruptcy notice from ES to help you understand the nature of this problem.  But first you must recognize the type of bankruptcy ES is filing.

Chapter 7 – This type of bankruptcy is the liquidation of remaining assets to distribute among its creditors.

Chapter 11 – This a financial reorganization of a business, which allows your client to function while they follow court ordered debt repayment plans.

Chapter 13 – Similar to Chapter 11, but rather than a business filing bankruptcy it is the individual reorganizing and following a debt repayment plan.

Ideally, it’s more favorable on your end if your client files for either Chapter 11 or 13.  These types of bankruptcy give your client a breather until they figure out how to repay.

If your client however files for Chapter 7, which is what ES filed, not only will your chances of getting paid be reduced, but also you may be waiting a long time (even years) for this type of case to be completed.

Take A Number

At this point you are probably frustrated and would like to call someone to attempt to collect your money.  Stop right there!  Your actions can get you in deep waters.  If you attempt to make phone calls to ES’s accounting department, send nasty letters, or try to file a lien (which some appraisers have done in other instances and is not recommended), you will face penalties.

Assuming you do get some money owed to you, you will have to wait in line.  This is the second item you must understand.  Here’s the payment order:

  1. Lawyers, administrative expenses, and other professional services that are involved pulling hairwith the work of filing the bankruptcy.
  2. Secured claims, including mortgage holders.
  3. Priority claims, including wages and taxes.
  4. Unsecured claims, which is where you as an may be categorized.
  5. Equity claims, including stockholders.

So curb your frustration because all you can do at this point is wait.

What Can You Do While You Wait

Sure you have to wait for ES’s bankruptcy process to take its course, but there are some things you can do in the interim.  Since this case can drag for a long period of time, you can do the following:

  1. Consult with your CPA about taking a deduction on your taxes for the bad debt.  If you manage to receive some money owed to you after the bankruptcy case is settled you can claim it as income at that time.  See your accountant for more details.
  2. It does not apply in this case, but if you have a future instance where your client files for Chapter 11 or 13 and wants to continue a working relationship, it may be to your advantage.  Of course your immediate reaction is to quickly say “no way!”, but understand that Chapter 11 and 13 require debtors to stay current on all accounts moving forward.  This means you can add a fee to your to recover what was lost, stricter payment time frames, and maybe exclusivity as other appraisers may not take another chance.  Keep in mind that the best way to reduce or eliminate risks is to get paid up front.

 Improve And Move On

Now that you’re somewhat familiar with the types of bankruptcy, payment pecking order, and what you may be able to do as the bankruptcy takes its course, it is important prepare for the future.  This means assessing your and how to prevent this problem from happening again.

First, create a process on how to screen new clients by knowing their payment history.  There are many tools and resources you can use online that are free or for a small fee.  Second, improve your accounts receivable aging management procedures.  Just because they are still “current” doesn’t mean it does not require all of your attention.  Current receivables can quickly turn into problems if you don’t pay attention.  Last but not least, be persistent and tough but professional with your collections.

If you have an AMC bill in your state, read it and educate yourself on how it can help your appraisal business.  There are sections in most AMC bills that require AMCs to pay by a certain time frame.  For example, Texas AMC bill requires AMCs to pay appraisers within 60 days.

Also consider resources available to you such as your receivables where the risk of non-payment is transferred to the company.  In this case, you can get paid quickly without the responsibility of collecting and liability of non-payments.

No small business is immune to the unexpected, but you can certainly minimize you risks as work towards a successful 2013.

Guest blogger:  Ramir Rodriguez  represents Treasure  Valley Factors
in Fruitland, Idaho. He has  helped real estate  appraisers
understand how factoring can can help their business since 2009.
For more questions about factoring ,
please  email him at rrodriguez@treasurevalleyfactors.com
or visit his blog Factoring Helps or
website www.treasurevalleyfactors.com.
Twitter: @RamirRodriguez
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