Appraisal News and Business Tips

Fannie

Fannie Mae – buy backs, adjustments, MLS fotos, etc

By Steve Costello, www.appraisalport.com

Steve reports on an educational session he attended at The Appraisal Institute (AI) annual conference in Austin, Texas, on Aug. 4-6, 2014. He also includes information from an Appraisal Institute seminar – Unraveling the Mystery of Fannie Mae Appraisal Guidelines

If you work for lenders, it is highly recommended that you read a summary of these recent changes for yourself in Announcement SEL-2014-03, dated . It can be found at
https://www.fanniemae.com/content/announcement/sel1403.pdf

Lenders are still concerned with buy-backs, where Fannie makes them buy back loans that Fannie purchased. Yes, they are happening today, sometimes due to appraisal “problems”.

Excerpts:

The ongoing scrutiny and updating of the Guidelines, combined with all these recent problems, are the reasons your lender and AMC clients now have to take great care screening your appraisal for any type of error. These days, it isn’t uncommon for a lender to be forced to buy back a loan that is still performing because an issue was discovered with the appraisal after the loan was sold on the secondary market. Many of the common UAD errors that cause problems may not have a direct effect on your final value, but these types of errors can still cause the lender to have to buy back a loan.
….
Another area of close attention by Fannie Mae that Underwood mentioned is the proper supporting of adjustments. Fannie Mae has determined this to be a problem area based on the volumes of appraisal data they examine. Just saying you made an adjustment is not good enough. You now need to show how and why you are making the adjustment. They found a lot of appraisers using “standard” amounts for adjustments. Many of these are old and outdated or no longer apply to a particular neighborhood. Fannie Mae is now looking for the appraiser to completely document how they arrived at their adjustments for any given property.

Note: Fannie Mae has said that they are especially looking to see some support for the adjustments made for gross living area and those items on the adjustment grid above gross living area, which include such attributes as the room counts, location, site and so on. How did you decide how much to adjust?

You may find some of Fannie Mae’s requirements surprising, but remember your lender may have different, more stringent requirements. Be sure to meet the requirements of your client even if they are above and beyond the Fannie Mae requirements.

A few Fannie guidelines you may not be aware of:
– Acceptable photographs include original images or those from MLS or the appraiser’s files. (If you can’t get to the comp, for instance in a gated community, you can use the MLS photos from the sale but make sure to document what you did).
– The appraiser must identify items that require immediate repair and deferred maintenance items which may or may not require immediate repair.
– Market condition adjustments must reflect the difference in the market conditions between the contract date of the comparable and the effective date of appraisal for the subject. (The adjustment may be either positive or negative).

 

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Fannie's new Collateral Underwriter to check appraisals Using Fannie's Big Data.

Fannie’s new Collateral Underwriter to check appraisals Using Fannie’s Big Data. 

Another great email from Dave Towne in Washington!!

10-14 FNMA Collateral Underwriter Flyer showing info about the FNMA Collateral Underwriter process they will make available to lenders (NOT APPRAISERS) in January 2015. You should review it. It has to do with their Enhancement of Risk Controls.

This is what we know as Appraisal Quality Monitoring (AQM) …. which was announced almost 2 years ago. FNMA has already been using the ‘scope’ on your reports, but will soon allow the lenders to have access to the software so that they can do pre-submittal exams prior to uploading the loan file, and your appraisal, to FNMA.

Virtually everything is digital now in our real estate appraisal world. That makes it incredibly easy for ‘big data’ to be analyzed very quickly and efficiently. Hiding relevant property info under a rock, your clipboard [tablet?], or just ignoring it, is no longer possible. Discrepancies will be found fast, and you will be asked for explanations or corrections.

Note the examples from the flyer:
– Chain of property ownership
– Inconsistency in reported property data from your info compared to your peers (subject & comps)
– Checking adjustments made (or not made) – primarily the math
– Testing for comps in terms of location, characteristics, sales prices, etc.

FNMA’s news release about their Collateral Underwriter:
Introducing Collateral Underwriter
Collateral Underwriter™ (CU™) is a proprietary appraisal risk assessment application developed by Fannie Mae to support proactive management of appraisal quality. CU will:
– Provide additional transparency and certainty by giving lenders access to the same appraisal analytics used in Fannie Mae’s quality control process.
– Perform an automated risk assessment of appraisals submitted to the Uniform
– Collateral Data Portal® (UCDP®) and return a CU risk score, flags, and messages to the submitting lender.
– Be available at no charge so lenders can take full advantage of the application for quality control and risk management purposes.

The CU risk scores, flags, and messages will be available to all UCDP users in real-time beginning on Jan. 26, 2015 through UCDP. Find more information on the CU web page at https://www.fanniemae.com/singlefamily/collateral-underwriter?cmpid=sln102114 .

Dave Towne, AGA, MAA Owner / Educator
360-708-1196
towneappraisals@clearwire.net
www.towneappraisals.com
Mount Vernon, WA

My comments: The PDF only has three pages of the document. The other pages were not available. Real estate is location, location, location. What about the 4th approach to value: Curbside Approach. That is where you sit on the curb across the street from the subject and ask yourself: “Does this value make any sense?”

There are many appraisal review programs in use and being developed. I knew that Fannie would be using their Big Data to automate underwriting reviews of appraisals as well as monitoring appraisers.

Does this mean appraisers focus even more on making sure their appraisals pass these automated reviews rather than focusing on what counts – the value? Is this another path along the way to not focusing on what appraisers provide – reliable and accurate values? Plus, disclosure of any problems with the property?

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New Fannie Appraisal FAQs including 1004MC

New Fannie FAQs – Appraisal and Property Related Frequently Asked Questions (FAQs) including 1004MC guidelines Published September 23, 2014

Fortunately, the document indicates which Q&As are new, as it is often hard to figure out what is new and what has already been sent out in other documents.

If you do lender work, read this document!!

Topics include:
– Comps with accessory units
– C&R ratings
– Comments on adjustments
– Sales over 12 months old and distance from subject – Ok to use
– Legal, non-conforming and proof of rebuilding – not required
And many more relevant and useful Q&As, including guidelines that have been around for a while, such as Net adjustments, etc.  Looks like Fannie has figured out many of the topics relevant to appraisers!!

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For many appraisers, the 1004MC comments will be very helpful:

Q16. What type of properties are to be analyzed for the data reported in the One-Unit Housing Trends portion of the Neighborhood section of the appraisal report form?

The data regarding trends to be reported in the One-Unit Housing Trends section must be reflective of those properties deemed to be competitive to the property being appraised. Additional commentary should be provided on the other segment(s) of the neighborhood when segmentation is present to aid in understanding the overall neighborhood dynamics.

Q17. Are the trends that are reported on the Market Conditions Addendum to the Appraisal Report (Form 1004MC) the same trends that are to be reported in the One-Unit Housing Trends section of the appraisal report (Form 1004)?

Yes. The conclusions regarding trends that are obtained from the Form 1004MC must be the same trends reported in the Neighborhood trends section of the Form 1004. The information reported on both forms must be consistent to provide the lender with a clear and accurate understanding of the market trends and conditions present in the subject neighborhood, based on properties that are considered competitive with the subject being appraised.

Read the additional 1004MC Q&As.

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Thanks to appraiser Dave Towne for some great comments on 1004MC:

Ever since the blasted MC Form was mandated in 2011, I’ve been saying the way appraisers have been ‘classically’ trained and used the Neighborhood check boxes on the primary forms did not mesh with the MC Form requirement.  (And in fact, I quit doing the ‘classic’ method then, and have been doing what Q16 & Q17 below say.)

I happen to believe one reason why the MC Form was instituted was that this ‘classic’ reporting methodology of reporting overall dissimilar neighborhood property trends (heterogeneous properties) did not (and does not) make sense when the assignment is to appraise a single property using comparable (or competitive) properties.

Dissimilar properties seldom have the same trend components that the comparable (competitive) properties have.  As such, they don’t need to be reported…..except as the last sentence of Q16 says …. ”Additional commentary should be provided on the other segment(s) of the neighborhood when segmentation is present to aid in understanding the overall neighborhood dynamics.”

An issue with the ‘classic’ methodology is the “predominate” value of an overall neighborhood with dissimilar properties can be much different than when only comparable (competitive) properties are used in the trend analysis.  So, when appraisers use the proper properties as outlined above, there should be no significant problems with that data point, because the “predominate” value will more than likely fall within the price range of the comparable (competitive) properties.

My comment: Finally some guidance on issues that have been driving appraisers crazy with lots of differing appraisal opinions. Now, we can use answers directly from Fannie!!

Hopefully, AMCs and lenders will use these Fannie guidelines instead of making up their own. Particulary, the guidelines that have been around for a long time that are repeated in these FAQs. You can refer them to this document.

Link to FAQs
https://www.fanniemae.com/content/faq/appraisal-property-report-faqs.pdf

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Appraisalport poll comments and results on 1004MC (from their Sept. 2 blog posting at www.appraisalportblog.com

“This month, I want to take a closer look at two recent polls – one related directly to the use of AppraisalPort and the other concerning a controversial form. Starting with the form, we asked: What do you think about the 1004MC form? This was a popular poll with a total of 5982 responses. The form doesn’t appear to be well thought of; with 66 percent of respondents selecting the answer “It really doesn’t work well and should be retired.”  Another 21 percent answered that “It is OK but in need of some updating or modifications.” It seems that the 1004MC form is going to have some trouble getting a date to the prom because only the remaining 13 percent of voters said “It still gives the client a good idea about current market conditions.”

“I did receive some additional feedback on this poll. Some appraisers just don’t like to use the 1004MC because it’s just something else that has to be done; takes more time out of the day; and may not provide accurate results – especially in rural areas. Others think it really is the first step to a more modern style of computer-assisted appraising.“

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Appraisers receiving warning letters from Fannie about discrepancies in Q and C ratings

I keep reading online about appraisers receiving warning letters from Fannie that they are using different Q or C ratings on the same property.

Of course we do change our opinions about a property. Sometimes we have new information or just re-think the property and change our opinion. Be sure to explain this in your appraisal.

You need to set up a way to use your comp database to check the Q and C ratings for any property you use in your appraisals. It should only take a few minutes. Hopefully software vendors will automate this for you. Bradford has software for this.

What happened to the appraisers who got the letters? Nothing that I heard of. But, Fannie may be putting them on a special list so their appraisals are scrutinized. Fannie has stated for awhile they would be sending warning letters.

Why is Fannie looking at Q and C ratings? Who knows why they picked these factors. Maybe because they are absolute. But, I suspect that other factors are being looked at or will be coming soon. I don’t think they would want to get into the very hot issue of GLA…

Remember, Q and C ratings are absolute, not relative. If you don’t agree with this, don’t do appraisals for Fannie Mae loans as that is in their Scope of Work.

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Fannie's Appraiser Quality Monitoring(AQM) FAQs July 2014

I did not compare these FAQs with the 2013 FAQs but they seem very similar.

The Q&As below may be new or revised:

– Will appraisers have the opportunity to appeal or offer a rebuttal?

– What should an appraiser do if he or she believes that the rebuttal would violate the Confidentiality section of the Ethics Rule as set forth in the Uniform Standards of Professional Appraisal Practice (USPAP)?

– What actions will Fannie Mae take with respect to specific appraisers?
Part of the reply: Fannie Mae will provide information directly to appraisers whose appraisal reports exhibit a pattern of minor inconsistencies, inaccuracies, or data anomalies. The intent and expectation of communicating these issues to appraisers is for training and educational purposes, and to provide them with an opportunity to improve their work. Future appraisal reports from those appraisers will be monitored to assess improvement.
https://www.fanniemae.com/content/faq/appraiser-quality-monitoring-faqs.pdf

Fannie posts a list of appraisers subject to 100% review of their appraisals or are not approved to do appraisals for Fannie Mae loans. The Appraisal Quality Management list is only accessible to lenders who sell loans to Fannie. The last list was posted in May.

My comment: Maybe a few of those appraisers hiring armies of people to do their inspections and drive comps will get caught. For example, completing 40 appraisals a week in urban areas or 10 appraisals a week in very rural areas. Of course, they can make lots of money working for very low AMC fees!!

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Changes to Fannie's Selling Guide dated April 15, 2014

Fannie’s Selling Guide, which includes appraisal guidelines has been updated.

Be sure to use the new Selling Guide to find out what Fannie really says vs. what your client thinks Fannie says!!

Summary of appraisal changes

New or Updated Policies
Chapter B4

Some of the new requirements/changes:

Added the requirement that a front photograph of the subject must be taken when completing the Appraisal Update portion of the Appraisal Update and/or Completion Report (Form 1004D) to validate that the appraiser has inspected at least the exterior of the property when he or she performed the
appraisal update.

Unpermitted additions
If the appraiser identifies an addition(s) that does not have
the required permit, the appraiser must comment on the quality and appearance of the work and its impact, if any, on the market value of the subject property.

Older Comparable sales
Revised the policy by removing the requirement that an explanation is required when using a comparable sale that is older than six months

Provided an example to illustrate that in some instances it
may be appropriate to use older sales with proper time
adjustments rather than a dissimilar more recent sale.
An older sale may be more appropriate in situations when
market conditions have impacted the availability of recent
sales as long as the appraisal reflects the changing market
conditions.

Information related to Fannie Mae’s acceptance of unique
property types has been provided.

The definition/characteristics and the eligibility of an
accessory dwelling unit have been provided.

Be sure to use the new Selling Guide to find out what Fannie really says vs. what your client thinks Fannie says!!

Link to summary:
https://www.fanniemae.com/content/announcement/sel1403.pdf

Link to new Web based documents:
https://www.fanniemae.com/content/guide/selling/index.html

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Info on Fannie's "do not use" appraiser list available

Info on Fannie’s “do not use” appraiser list available

Many thanks to appraiser Dave Towne for sending the email below!!

FannieMae distributed this info below on 1/07/14 ….. shown here just as an FYI, because appraisers cannot access the AQM page.

But you can access the LL-2013-10 which describes some of the negative reporting issues the GSE’s have seen since the UAD was implemented.

Your UAD reports are subject to a higher level procto exam if:
–>you often use the same comp in different reports, but the data you report for that property is different between reports
–>you change the Quality and Condition rating for the same property used as a comp in different reports  (The first time it’s used the Q & C ratings should ‘stick’ thereafter)
–>you are contacted by a GSE reviewer who discusses the above item(s), and you don’t have a credible explanation as to why you have done the above
–>you continue to make the same reporting errors frequently

If you wind up on the GSE’s ‘do not use list’ you are effectively out of business – at least for federally regulated mortgage lending reports.  So “let’s be careful out there!”

Appraiser Quality Monitoring Information
Fannie Mae has published a new web page with information about the recently implemented Appraiser Quality Monitoring (AQM) process. The new AQM web page includes FAQs and a link to the AQM list identifying appraisers whose appraisals will be subject to 100% review by Fannie Mae or whose appraisals are no longer accepted by Fannie Mae. The AQM list is protected content, and approved Fannie Mae sellers/servicers may set up access through Technology Manager.

For more information, refer to Lender Letter LL-2013-10: Appraisal Quality, which reminded lenders of Fannie Mae’s appraiser selection requirements, highlighted several data quality issues, and described the AQM process that Fannie Mae has implemented to identify and monitor issues with individual appraisers.

Direct link to Fannie Appraiser Quality Management (AQM) web page at  www.fanniemae.com/singlefamily/appraiser-quality-monitoring

Dave Towne, AGA, MAA                                             towneappraisals@clearwire.net                           www.towneappraisals.comMount Vernon, WA

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What do I think? This can be good for the appraisal profession!

Appraisers have been complaining for years about the “other” appraisers who are unethical, incompetent, lazy, or stupid. For many clients, since licensing, all appraisers are seen as the same. Why not use someone who gives you what you need – turn time, fee, no problems with underwriting, etc.?

Unfortunately, AMC hassles have driven many very experienced appraisers out of the business, or refusing to do AMC work. This makes the problem more difficult.

Maybe more AMCs will start using appraiser quality rather than fee, turn time, etc. to select their appraisers.

Also, the preference by many AMCs for low fees makes it very tempting to skimp on the time and effort for doing appraisals.

A low fee does not mean that you can do a poor job on an appraisal. I know what it is like to work for a low fee. I tried doing low fee jobs a few times over the years, but found I had a really “bad attitude” about the appraisal and had to force myself to do the same appraisal no matter what the fee. Doing a good appraisal is more important to me than using a low fee as an excuse for doing less work on an appraisal.

It is great to see that Fannie is using objective criteria, rather than a reviewer that gives an appraiser a bad rating, removing them from the list of a major lender. Just like appraising, reviewing is subjective. Particularly with the use of reviewers not familiar with your local market.

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