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!!

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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/

VA loans up and FHA loans down

VA loans up and FHA loans down because FHA increased its mortgage insurance cost
Excerpts:
Of the 16.4 million active-duty service members and military veterans with mortgages, less than 12% have a loan guaranteed by the Department of Veterans Affairs.
A sharp increase in Federal Housing Administration mortgage insurance premiums is making the VA more competitive, according to Megan Booth, senior policy representative at the National Association of Realtors.
“There is not a Realtor alive today that thinks FHA is a better deal” for veterans, Booth said. “That is helping the VA grow and it will continue to help the VA grow.”
VA lenders originated a record 629,300 single-family loans in fiscal 2013, which ended Sept. 30. The agency endorsed 90,820 single-family loans in the fiscal second quarter, totaling $20.1 billion, down 10.5% from the prior quarter. FHA endorsements declined at twice that rate over the same period. Sixty-three percent of VA loans are going to homebuyers rather than for refinancing, according to agency officials.
…..
Meanwhile, lenders continue to complain that there is a shortage of VA-approved appraisers and underwriters, which slows processing times. …
But the VA is becoming more responsive. “VA is trying to get more appraisers and weeding out the bad ones,” Booth said at the conference.”

http://www.nationalmortgagenews.com/news/origination/underused-va-mortgage-program-makes-inroads-as-fha-costs-rise-1041954-1.html

If you can’t access the full article without registering, there is a summary at: http://realtormag.realtor.org/daily-news/2014/06/13/va-loans-gain-popularity-fha-costs-rise

The June 2014 issue of the paid Appraisal Today had an article on how to get on the VA panel. It is very different than applying for panels for AMCs, Lenders, or FHA. No AMCs, C&R fees, appraisers treated as professionals, etc. I spent a lot of time interviewing many appraisers and VA personnel to find out about reference letters, re-applying, etc.

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Second unit or accessory dwelling?

Source: www.sacramentoappraisalblog.com  – Ryan Lindquist
Note: Ryan’s blog postings are written for home owners in his area, but are often helpful for appraisers also.

Excerpts:

Is it a second unit or an accessory dwelling? How do you know the difference? If the post office gives the second structure an address, that makes it a second unit, right? Or if the dwellings are separately metered, it must mean there are two units. Let’s talk through some distinctions below, and then discuss a bit of a “monkey wrench” since there is an added subjective layer when making this call.

The Short Answer: A second unit and an accessory dwelling might look like the same thing to a casual observer, but what matters most in determining whether a structure is a second unit or accessory dwelling is what zoning allows and whether the market perceives the structure as a second unit or not. The post office might have a separate address for an accessory dwelling, but that does not make it a legal and legitimate second unit. The utility company might have two meters on site also, but even that does not mean there are two units. The key comes down to the property being legal as two units in the eyes of the city or county, recognized by the market as a second unit, and even how the dwelling contributes to value.

The Monkey Wrench: Part of determining whether something is an accessory dwelling or second unit comes down to its contributory value, and the appraiser is really going to have to give this some thought…

My comment: I’m working on an appraisal of a property that has two legal homes on one lot. The front house is 2 bedroom/1 bath 1,500 sq.ft. The rear house is 2 bedroom/1 bath 1,000 sq.ft. In my city, most detached units are small “cottages” behind much larger homes and are marketed as homes with an extra unit and as duplexes. Most sell as homes with a small rear unit. Of course, when I got to the property, I found out the rear unit was much larger than the typical rear cottage!! Our market is very, very strong with a shortage of inventory. Many buyers are priced out of the sfr market and are looking at properties with 2 units, but they want a unit with at least 3 bedrooms for owner occupancy. I am still trying to figure out how my subject fits into this market as the front unit lacks a third bedroom, but does have a small room that could be used as a child’s bedroom. I am interviewing lots of agents and going on the weekly open home caravan looking at listings. Fortunately, this is not for a lender so I can take extra time to figure it out!!

http://sacramentoappraisalblog.com/2014/06/17/is-it-a-second-unit-or-an-accessory-dwelling/

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How to use Google addresses in your appraisals!!

How to use Google addresses in your appraisals!!

Google’s Street View is doing photos all over the world!!

I used to spend a lot of time doing preliminary research on an appraisal by looking up property data on public records. Now, I just google the address!! Google provides a front photo and the search often includes other services such as zillow and trulia that provide public records data.

Someone calls or emails you about an appraisal. Hopefully, you check out the property before you decide whether or not you want to do the appraisal and decide your fee. Just google the address!! You can do it in your car with your smart phone.

Do you ever get back to the office and notice that your comp photo doesn’t match the MLS photo or, more likely, you are not sure you are selecting the correct photo?
You sometimes can also zoom in on google photos to check the address of a property.

Living in a rural area? Keep a lookout for a Google car,motorcyle,bicycle,camel,?? They seem to be everywhere!!! Or, just check out your relatives’-friends’-ex’s-child hood homes. It is endless!!

Click here to see where Google is now, has been, and where it is going?
https://support.google.com/maps/answer/68384?hl=en

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The Big Issue for Appraisal Fees – Consumers are paying more for appraisals if AMCs are used

The Big Issue for Appraisal Fees (if you want to get higher fees) – Consumers are paying more for appraisals if AMCs are used

There is only one relevant consumer issue: they are paying more for appraisals since AMCs took over.

They just want to get their loan. Why would they care about the appraiser? Plus, much more complicated issues such as Dodd Frankenstein, AMCs, etc. etc. are very difficult to understand for consumers. Lenders don’t care. They just want to pass their regulatory audits and sell their loans to investors.

I have no idea why appraisers don’t promote this simple message.

You could change the pitch to all consumers in the U.S. : “Why have borrower’s appraisal fees gone up?” Nobody cares about what appraisers are paid, except appraisers and a few others. Everybody, including appraisers, does not want to pay for inflated appraisal costs.

But, for appraisers, AMCs are a much easier target. AMCs work for lenders and do what they want.

I have been hearing that a few direct local lenders have started changing their fees up and down depending on the market. I don’t know why they hardly ever changed their fees before.

FYI, before licensing and mortgage brokers, lenders managed their own appraisal departments but didn’t change fees much and there was no or little bidding (residential) – since the 1930’s, when lender regulators started requiring appraisals and American appraising took off.

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What are customary fees?

I don’t know. AMCs have about 80% of the market. What is left for lender fees? VA (doesn’t change fees very often) and direct lenders are dropping fees.

What about non-lender fees? With borrowers paying lots more for appraisals, I keep increasing my fees to well over customary lender appraisal fees. They are still less than what borrowers are paying.

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Japan's disposable homes

During my morning walks, I listen to podcasts. One of my favorites is Freakonomics Radio (Yes, the same guys that wrote the book)
I recently listed to a podcast where they analyzed Japan’s very unusual home sale market. They consider many homes to last about 20 years (economic life) and then they are demolished and new homes built.
A few excerpts from the summary of the podcast:
It turns out that half of all homes in Japan are demolished within 38 years – compared to 100 years in the U.S.  There is virtually no market for pre-owned homes in Japan, and 60 percent of all homes were built after 1980. In Yoshida’s estimation, while land continues to hold value, physical homes become worthless within 30 years. Other studies have shown this to happen in as little as 15 years.
In the podcast, we look into several factors that conspire to produce this strange scenario. They include: economics, culture, World War II, and seismic activity.
Richard Koo, chief economist at the Nomura Research Institute, has argued in a paper called “Obstacles to Affluence: Thoughts on Japanese Housing” that whatever the rationale behind the disposable-home situation, the outcome isn’t desirable…
My comment: Fascinating and worth listening to!! Very interesting for appraisers, especially.

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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
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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!!

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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)

Voluntary Appraiser Disciplinary Action Matrix Based on 2014-15 edition of USPAP

A very interesting document provided by the Appraisal Foundation to state boards. Not mandatory, just information for them. State boards vary dramatically in how they handle discipline. Fortunately, I am in California, which has never had a state board (Governor of CA at that time did not want to increase any expenses, including advisory boards). Investigators are all state employees.

3 examples:

An appraiser states in his certification on an appraisal that he inspected the interior and exterior of the subject property, when in fact he only drove by the property.
As a result, he stated that the subject property was in average condition when it was actually in poor condition and essentially uninhabitable. He did not use any extraordinary assumptions or hypothetical conditions in the assignment. He knew that the lender required an interior inspection.

An appraiser accepted an appraisal assignment in an area where he is not geographically competent, failed to notify the client that he was not geographically competent and failed to take the necessary steps to become competent. As a result, he produced an appraisal that was not supported by market data.

In the sales comparison approach, an appraiser simply adds the adjusted value of the three comparable sales used and divides by three for an indicated value, even though some sales were far better indicators of value than others.

Note: These are the simple examples. There are more commercial appraisal examples and more complicated residential examples.

Click here to download from the Oklahoma state regulator web site.

My comment: Well worth reading. What does your state board do?

Thanks to Long Time Reader and author Doug Smith in Montana for this great link!!

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  Read more!!

Review appraiser liability

By attorney Todd F. Stevens

Excerpts:
Here’s a trend in real estate law: attorneys are waking up to the potential liability of review appraisers. Couple this with the common misunderstanding among review appraisers that their risk is less than the author of the original report, and you get a burgeoning new area of litigation. Here’s how to protect yourself.

Another big myth is that reviewers have less liability than the original appraiser. In fact, I have heard some attorneys argue that reviewers have more liability than the original appraiser since reviewers have the “last” opportunity to correct any problems with the report. While I am unaware of any case precedent specifically addressing this issue, logic dictates that the liability of a reviewer and the original appraiser are the same.

My comment: a topic that appraisers who review appraisals don’t like to think about. This article was written several years ago and refers to mortgage brokers, but it applies now. The author defends appraisers.

http://www.keenlaw.com/topics/reviewappraisals.html

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