Appraisal client requests for clarification

AppraisalPort Weekly Poll Analysis – client requests for clarification
By Steve Costello, AppraisalPort Product Manager

I receive a lot of e-mail from appraisers commenting about the time they spend working onstress - hitting head on keyboard requests for clarification on appraisals they have submitted to their clients. That prompted me to post two polls related to these client requests.

“What percent of your assignments result in a request for clarification from the client?
The results were a little different than expected with nearly half (45%) of the 4,691 respondents stating that they only get a clarification request 0%-10% of the time. That is actually lower than expected based on what I hear from appraisers directly.
The second most popular answer was 11%-20% of the time with about 19% of the vote. The number of votes continued to get smaller as the percentages increased (13% chose 21%-30% while another 8% answered 31%-40%).
After that, things take a bump up. Nearly 15% of the appraisers responded that they get a request for clarification on more than 40% of their appraisals. I can see where that level of requests could make it difficult to get the new work completed on time.

“How often does your client requests information that is already in the original submitted report?”
In other words, we are asking how many of the above requests for clarification were un-necessary because the client already had the needed information.
This was a popular poll with 5,632 responses and the overwhelming answer was “often” with 60% of the vote.
About 27% responded that they “rarely” run into this situation while only 1% said it “never” happens to them.
Another 12% answered that this “almost always” happens.
So it looks as if we have a fairly large number of appraisers being asked for additional information that is already contained in the report.

My comment: nothing new here but I do like the analysis of the data. I love working for my estate clients. The dead people never request any clarifications (except maybe their executor contacts me when I have the wrong subject property address) ;>

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ES AMC out of business

ES Appraisal Services/Evalonline.com/Evaluation Solutions AMC in bankruptcy and is outclosed fighting over dollars of business

Another AMC closes its doors. I have been predicting AMCs going out of business for a long time. Why? The cost of starting a national AMC is in the millions. To handle cash flow problems, such as losing a main client (ES and JVI are examples) millions more are needed in cash reserves. There are over 400 AMCs now since HVCC in 5/09. I don’t know how many have lots of cash reserves. I suspect that many don’t. It is very similar to an appraisal business being dependent on one client and then losing the client. Nothing new.

ES is in bankruptcy. Employees and back payroll taxes must paid first. Vendors/suppliers typically don’t get much.

What is surprising to me is how many appraisers keep accepting orders, even though there are many Internet postings about them, often for many months.

A few months ago, in the September 2012 issue of my paid newsletter, I wrote about how to collect from AMCs. It is not that hard. It is not that hard. I will be setting up a special AMC Watch List for my paid subscribers. To subscribe to the newsletter, click the banner below.

I have always known which AMCs were in trouble long before they went out of business. Real estate agents have been complaining for 2007 about BPO payment problems. Appraisers started speaking up in early January, 2012.

In the January, 2013 issue I have a profile of a mid-size AMC including how I evaluated their financial strength and ability to handle a downturn.

Sorry, I can’t give it all away as I spend a lot of time on the research and writing ;>

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Why are there so many increasing lender/AMC requirements?

Today, lenders are very worried about investors requiring loan buy-backs. I keep hearing aboutpiles of paper minor appraisal errors, such as typos, resulting in buy backs. Of course, many of the loan documents, including appraisals, have been lost.

Is this realistic? I don’t know, but lenders are worried so they tell their agents, AMCs, to increase appraisal requirements. There were much more significant changes in 1989, such as appraiser licensing, that will not be reversed.

AMCs work for lenders, and do what they say. But, if one of an AMCs lender’s require something, that AMC may require that it be done for all of their lenders because it is too much of a “hassle” to send out separate engagement letters for each lender’s appraisals.

This is a short excerpt from an article in the January, 2013 issue of the paid Appraisal Today newsletter, which focuses on AMCs, including background checks and a profile of an AMC that pays well and that appraisers like to work for.

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Background checks

man with question mark

fbi badge

Another AMC/client issue is requiring background checks. Some AMCs are asking for them and some are not. If one of an AMCs clients’ asks for a background check, it is easier just to get one from the AMC’s appraisers so that it is in the AMCs files if they need it.

I’m working on an article for my paid Appraisal Today newsletter about this issue, including what the AQB advises and where to go to get one you can use for multiple AMCs. There are some good reasons why clients (and state regulators)

want them. I got a background check when my license 20 years ago and have never gotten another one. And some bad reasons – privacy invasion, cost, hassle, etc.
I’m working on a series of articles on AMCs for my paid Appraisal Today newsletter, including trying to find out about these background checks.

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Texas AMC fee survey – disconnect between AMCs and appraisers

dollars floatingThe Texas AMC fee survey was taken in August, 2012. In the results, 10% of the appraisers said they received under $250 for 1004s and the AMCs said they paid no fees under $250.

No one really knows why there is such a disconnect. Survey requests were sent to all licensed AMCs and licensed appraisers. Not all responded or could be contacted. Only AMCs licensed in Texas were surveyed. The Texas licensing started in March, 2012.

In this month’s issue of the paid Appraisal Today newsletter I wrote an article “What are AMCs paying now? Fees a

re going up, but some appraisers are still working for low fees” and used various fee surveys.

The Texas Appraisers and Appraisal Management Company Survey is by far the most rigorous and was done by three universities, and was requested by a committee of the Texas State Senate. The survey was done in 8/12 and the report was available in 11/12.
Link to survey: www.talcb.state.tx.us/pdf/Texas_Appraiser_AMC_Survey_Report_2012.pdf

This is the first in a series of articles about AMCs that I am working on.

Here are the other AMC articles I have written rece

 

ntly:
– November, 2012: Who’s on your “approved AMC” list and why? Dump your bad AMCs! AMC rating grid
– October, 2012: AMC and appraiser liability -claims, blacklisting, lawsuits, etc.
– September 2012: this issue focused on AMC collection – how to collect from deadbeats and get all your billings paid!
– August 2012: AMC fees are going up! Many appraisers are swamped with work! You CAN get higher fees!!Win-win AMC fee negotiation for appraisers
– April 2012: 8 reasons why AMCs ask dumb questions – written by an industry insider

FYI, my first article on AMCs was written in 1994.

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AMC asks appraiser to remove photos of black cat

black pantherHow the AMC  (maybe) saw the cat

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Fair lending violations per AMC.

This first circulated on the Internet in September. I finally found the original source!!

This was from the famous/infamous real estate and mortgage news and commentary videos with Frank Garay and Brian Stevens.

I love the “Frank and Brian” video show!! It is mostly about mortgage lending but is sometimes about appraisers. They used to have an appraiser version, but one of the two appraisers went to work for the CA state regulator, so it was discontinued.

Foto of the The Two Guys
http://tbwsworkshop.com/unm/wp-content/uploads/2011/03/Picture-8.png

Here’s link to the video to see them in action!!!
http://tbwsdailyshow.com/2012/09/18/real-estate-deal-delayed-by-a-cat/

AMCs and confusion about Chase and 30 mile limit

One of my readers contacted Chase after reading my email sent yesterday. The reader said that Chase question mark why?does not have any 30 mile limit. Per the email from an account executive at JPMorgan Chase in Florida: “No we do not have any such guideline or requirement like that.
Sounds suspect!”
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My original source for the info was Doug Smith in Montana, who received an official letter with a letterhead from Equifax stating that Chase has a 30 miles limit. Here is the emailed letter he received on 11/16/12:

“Attention all Chase Appraisers:

Effective orders assigned tomorrow, Friday November 16th, 2012, all Appraisers completing orders for J.P. Morgan Chase Bank must be within 30 miles of the subject property.“

“You will be asked during the assignment call from Equifax Settlement Services to confirm that the appraiser completing the order is within 30 miles.  Any assignment exceptions to this requirement will be noted in the Equifax order notes.“

“Please note, for both Equifax and Chase audit purposes it is IMPERATIVE that the appraiser’s address stated on the report is within 30 miles of the subject property address.“

“We thank you for your compliance with this new Chase requirement.“
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Afer inquiring about an order for an appraisal 100 miles from his office (not unusual in Montana), Doug also received an email from Servicelink saying that their contract with Chase did not have that requirement.

What’s happening? I have no idea. The emailed letter sent to Doug from Equifax is very clear.

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Chase has a new appraiser requirement – appraiser must be located within 30 miles of the subject

AppraisalPort Poll Results – 5/14/12Stop sign

In the past 6 months how many appraisals over 50 miles away from your office have you completed?
0 to 5, 3377 votes – 62%
6 to 10, 539 votes – 10%
11 to 15, 296 votes – 5%
16 to 20, 245 votes – 5%
More than 20, 985 votes – 18%

Total Votes: 5,442

My comments: Very interesting results!! Although the poll is for only over 50 miles, I would expect that more appraisers are traveling 30 miles or more. I guess Chase won’t be lending in rural areas or parts of large counties. I am 32 miles from the farthest city in my county. I am in the San Francisco Bay area, and most appraisers who work multiple counties travel over 30 miles one way regularly. Of course, the more time you spend driving, the less appraisals you can complete. Cutting driving time is the best way to increase productivity.

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Disaster appraisal form reports – be careful!! – from 11/12/12 email newsletter


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DO NOT FILL OUT ANY PART OF ANY FORM ASKING FOR YOUR OPINION OF VALUE (INCLUDING DIRECTION IN VALUE) AND/OR REPAIR COSTS. DO NOT INCLUDE ANY OPINION OF MARKETABILITY.

Forms that are being used

1. You are working for a lender who allows you send a letter. That’s what I did in 1999-2000 disaster inspection reports in my area. BEST OPTION.

2. FANNIE FORM 2075 OR FREDDIE FORM 2070. THIS FORM IS THE ONLY APPROPRIATE STANDARD FANNIE MAE FORM. This was used for many years for exterior inspections with no appraisal (comps, value, etc). You can discuss the condition of the home in a comments section.

3. Catastrophic disaster area property inspection report. I have seen these from three software vendors. All were different. Unfortunately, some of them have sections for reporting “cost to cure” and/or opinion of direction in value. You will have to modify them, similar to the discussion below on the 1004D. See what it looks in your forms software.

4. Fannie form 1004D – Appraisal Update and/or Completion Report. available 3/05. This form has been widely used by lenders, starting in 2005. See below. THIS FORM IS FOR AN APPRAISAL, NOT INSPECTION-ONLY. EVERYTHING BELOW THE TOP OF THE FORM (address, client, etc.) IS NOT APPROPRIATE. YOU MUST WRITE UP YOUR OWN SCOPE OF WORK, INTENDED USE, ETC. PUT THE APPROPRIATE INFORMATION IN NARRATIVE FORMAT IN A TEXT ADDENDUM. BE SURE TO PUT DISCLAIMERS ON BOTH PAGES OF THE REPORT IN THE COMMENTS SECTION PLUS THE ADDENDUM See below.

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Fannie form 1004D – Appraisal Update and/or Completion Report. available 3/05. This form has been widely used by lenders, starting in 2005, for appraisals “subject to completion”, typically new homes. These reports are done by the appraisal who did the original appraisal. THIS FORM IS USED BY AMCS AS IT CAN BE TRANSMITTED AND IS A STANDARD FORM.

THIS FORM IS FOR AN APPRAISAL, NOT INSPECTION-ONLY. ALL THE FORM BELOW THE TOP OF PAGE 1 IS INAPPROPRIATE AND MISLEADING.

Below that section, the only item that can be used is the Intended user. YOU MUST HAVE AN ADDENDUM DISCUSSING WHAT THE LENDER/CLIENT WANTS.

– You can put text comments info Conclusions on Page 2. Do not check any boxes. Do not fill in any repair estimates. Write up your description in the comments. Such as None apparent (do NOT discuss effect on collateral or marketability). Or, the home has been completely destroyed, except for the foundation. No roof, walls, etc.

– DO NOT FILL OUT ANYTHING IN THE RECOMMENDED INSPECTION SECTION. Repeat the above disclaimer. You can include a brief, general, description of the home in the comments section. Even if is there is no damage apparent, you did not previously appraise the home. Be sure to explain this. For example subject and nearby homes do not appear to have been affected by Hurricane Sandy.

NEIGHBORHOOD DESCRIPTION IS NOT INCLUDED IN THIS FORM AND IS A SIGNIFICANT FACTOR. The disaster forms and the 2075 form include a neighborhood section. Optionally, you may include a statement on neighborhood/nearby homes, such as “Almost all the homes within 2 blocks of the subject are almost completely destroyed” Or, the subject is 1 mile from any apparent storm damage.

You MUST write up your own addendum/letter, covering:

– Statements that:

THIS IS NOT AN APPRAISAL AND IS PROVIDED TO ASSIST THE LENDER AFTER A DISASTER. THE SCOPE, INTENDED USE, CONTINGENT AND LIMITING CONDITIONS, AND APPRAISER’S CERTIFICATION ARE SUPERSEDED BY THIS ADDENDUM. THE SIGNATURE PROVIDED ONLY INDICATES WHO DID THE EXTERNAL INSPECTION. ALSO PUT THIS STATEMENT BELOW “HAS THE MARKET VALUE DECLINED” SECTION. DO NOT CHECK THE BOX.

– Intended use. Do NOT include “To determine if the property has declined in value since the date of the original appraisal for a mortgage finance transaction.”

– Scope of work. ONLY include “perform and exterior inspection of the subject property from the street”.



BE SURE TO INCLUDE THE DISCLAIMER BELOW

“While the appraiser noted no VISIBLE damage, the appraiser is neither an engineer nor a contractor and is not qualified to comment upon whether or not damage may be present which was not apparent from a visual, exterior inspection.”

Source: Liability Insurance Administrators

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REFUSING TO FILL OUT THIS FORM. Some appraisers are refusing to fill out this form. This has the same problem since 2005. Nothing has been done about this. It is your decision. As you can see, it is not appropriate and only the first section of the form can be filled ouit.

If you choose to fill out this form, it is your choice.

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WHAT’S THE ANSWER? A standard disaster inspection report, used by all lenders.

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My last local disasters were in 1989/1990 – Oakland firestorm and Loma Prieta earthquake. I did re-inspections on properties I had previously appraised for lenders. No values or estimated costs, etc., of course. Most of the appraisal work was for insurance companies to determine the value of the property previous to the disasters.

The most recent large disaster was Hurricane Katrina in 2005. This was pre-HVCC and lenders ordered the property inspections as AMCs were not predominant. Many lenders ordered 1004D forms and many appraisers refused to fill them out.

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Be sure you can find the subject!!

GPS is not exact. A subject can be hard if there is nothing there and all the nearby homes are gone. I know from experience!! I had previously appraised the homes after a disaster and had difficulty finding them!!

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What about fees?

The primary factor is how much time it will take. You can work for any fee you choose, even $1, for any report.

Since you will not be providing any opinion of repair estimates, direction in value, etc. look at how long it will take you driving, research (finding the subject), writeup, and transmitting the report. Also, if you can do lots of them on the same day, in the same neighborhood.

I’m hearing from a minimum of $75 (low Fannie 2075 fee) to $200+ each.

If you are doing interior inspections, be sure someone accompanies you. Be very, very careful. Don’t do them for a low fee. They are probably ok in areas with minimal damage, such as broken windows, etc.

Appraisal Humor

Appraisal business tips

A very, very funny appraiser video!

What is an AMC? – from 11/20/12 email newsletter

What is an AMC?

In my last email newsletter, I mentioned Greg Stephens, an excellent speaker at Valuation Expo. I wrote that he worked for Metro West AMC. The actual company name is Metro-West Appraisal Company, LLC. It works in 40+ metropolitan markets. His company is not considered an AMC as there are only staff appraisers, with no fee appraisers. His clients do not want to use an AMC.

Dodd-Frank reference: AMC … “that oversees a network or panel of more than 15 certified or licensed appraisers in a State or 25 or more nationally within a given year…” Per Greg, this has been interpreted to refer to fee appraisers, not staff appraisers. Many state laws have clarified this. But, state AMC laws vary widely and some are more restrictive than Dodd Frank.

It looks like I will have to write an article for the paid Appraisal Today analyzing this issue. I have always thought of an AMC as a large appraisal firm that has some staff appraisers and mostly independent contractors, although in the past there was at least one large AMC that had no appraisers on staff. I don’t know of any AMCs today who do not have any licensed appraisers on staff. This stuff gives me a headache!!

Link to full email newsletter with info on JVI payments and new director for CA appraisal licensing dept