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.
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.
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.
On the plus side, now underwriters are only getting messages based on “rules”, not actual data. With CU, they will have more information to decide if something needs to be changed. I am sure that a lot of “flakey” appraisers who are not very competent, rush through appraisals too fast to get them done, etc. will be identified. More important, the really bad appraisers who may be competent but choose to use “fake” comps, change comp sales prices to get a higher value, etc. will be found out.
I am working on an article for my January 2015 newsletter on CU and am studying all the Fannie documents plus interviewing industry insiders to see what it means for you. Reading all these Fannie documents is giving me a headache!!
Go to www.fanniemae.com/singlefamily/collateral-underwriter and listen to Fannie’s two webinars for underwriters (listed under OnDemand eLearning Courses) – very good with excellent illustrations and explanations. 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.
Also listen to Jeff Bradford’s recent webinar athttps://goto.webcasts.com/viewer/event.jsp?ei=1050667 . It starts with the Big Picture of Big Data and discusses CU. It also includes information on his new Redstone report which has adjustment support and other information. Redstone can be attached as an addendum to any forms software you use. You can skip this part, if you want. But, I found it very interesting. Projected pricing is $5-$15 per report, depending on what you need. Jeff is writing an article on the Big Picture of Big Data for the February issue of the paid Appraisal Today.
Fees and getting C/R vary widely – per www.AppraisalPort.com polls
As you can see above, appraisers say that 60% or more of their clients are paying C/R fees
As you can see above, only 9% of appraisers say C/R is under $350. Yet, I suspect that many are working for under $350 fees. Looking at the poll above, 60% or more of respondents say are working for C/R fees. Are most of them doing a lot of non-lender work, VA appraisals, AMCs who pay C/R, or direct lenders?
As you can see from the two polls, they show that 60% of residential appraisers say they are getting $400 or more per appraisal. If you’re not in the 60%, its time to change.
But, somehow the results seem strange to me. With AMCs at about 80% of the lender market and limited non-lender work available (as compared with commercial appraising) who are the 60% of the appraisers working for? If it is accurate, it means there are lots of clients paying C/R fees…
If you want to get higher AMC fees, you must:
1. Ask for higher fees and
2. Dump cheap AMCs
3. Only bid on jobs that won’t take much time and have few revision requests
Why don’t appraisers do this? Fear and Greed, just like all other businesses. Fear – afraid they will never get another appraisal job. Greed – want more money now. You have to overcome this to be successful in today’s very competitive AMC appraisal market. It is your choice to work for low fees and very demanding clients.
Next month’s paid Appraisal Today newsletter will have an article on how to overcome Fear and Greed and get higher fees.
Fannie warning letters-GLA adjustments
Fannie has been sending out warning letters to appraisers about variations in Q and C ratings. Now they are sending out letters about using low GLA adjustments. According to people who attended, or heard about a recent speech that Bob Parsons of Fannie Mae gave an appraisal conference, $25 per sq.ft. Seems to be used by lots of appraisers for lots of properties that vary widely in size, etc. I wasn’t at the speech and don’t know what was actually said, but $25 per sq.ft. Was used in a large number of appraisals.
A quote from a recent email I received: “A friend of mine just got a letter from Fannie Mae stating that they have been monitoring his reports for 6 months. In that time they said he used $35 Psf for gla adjustments 14 times. This is a warning. Further action may be required if this continues.” I haven’t seen any of the letters myself but have been hearing about them for a few months. This The last two sentences have been pretty common in the warning letters sent about Q and C adjustments, which are a lot more shakey to support and are much more controversial.
Hmm… In my area, the San Francisco Bay Area, with a median home price of $601,000 in October, 2014, slightly down from June as many markets have slowed down. San Franciso’s median home price is around $1,000,000. I hope no one there is using $25 per sq.ft.!! Except maybe in neighborhoods with relatively low home prices or some lower priced condos condos. In my small city of 75,000 population the median price in October 2014 was $690,000. Our prices are around the median for the area. Very few homes or condos under $300,000.
Sq.ft. is one of the easiest adjustments to support, as compared with lots of other features. For many years, it has been one of the few almost always reliable adjustments when using regression analysis. You can sometimes even use matched pairs. I have no idea why appraisers don’t try to figure out an appropriate adjustment.
This is just a start. Read info on Fannie’s “UCDP Fannie Mae Appraisal Messaging Change Notification” – link below, with a list of all of the appraisal data that Fannie is looking at below.
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Dave Towne on Collateral Underwriter
Thanks to appraiser Dave Towne (again) for his Most Interesting Comments:
Appraisers……..
Many know by now that the GSE’s…primarily FannieMae……..have instituted a new ‘appraisal scoring’ procedure based on an electronic read of your reports ……….. specifically on a SFR 1004 or the Condo 1073. Those are the only forms currently being analyzed by the CU process.
On Nov. 18, 2014, FNMA released a document named “UCDP Fannie Mae Appraisal Messaging Change Notification” which you can find here: https://www.fanniemae.com/content/release_notes/ucdp-change-notification-01262015.pdf
I encourage all appraisers to actually read this document … all 11 pages.
When you do read this document, you will learn that your reports are being compared to your peer’s reports, and to your other reports, and to some unidentified ‘model’ FNMA uses.
Some of the ‘checks’ being performed by the CU process include these:
The reported GLA is materially different than what has been reported by other appraisers.
The reported lot size is materially different than what has been reported by other appraisers.
The condition rating is significantly different than what has been reported by any other appraiser.
The quality rating is significantly different than what has been reported by any other appraiser.
Here are a few that can cause real concern among appraisers:
The GLA adjustment is larger than peer and model adjustments.
The GLA adjustment is smaller than peer and model adjustments.
The view adjustment is materially different from peer and model adjustments.
And I just love this one:
The appraiser-provided comparables are materially different than themodel-selected comparables.
It’s time for appraisers to get serious about meeting your peers in person, compare notes, and develop a regional adjustment chart for all variables … much like that yellow legal pad paper you were handed when you got in this business …. that paper with the ‘required’ adjustment amounts on it for almost all items.
Oh … and when you get that knuckle slapping letter from FNMA saying your adjustments or comparables don’t match the ‘model’ be sure to get the specifics and pass on ‘model info’ to your peers.
Yep, appraising real property and developing an opinio
My comment: Fannie, please send me all my adjustments. Then I won’t get questioned by my state regulator (hopefully), underwriters, reviewers, etc. I would really like to know what adjustment to be made for all the unusual features in the homes I typically appraise – most built before 1930 and many built before 1910 with all types of additions, remodeling, etc. Even tract homes have stuff like converted garages, original kitchen and baths, inlaw units in rear, views, etc. Of course, I have been using regression since the 1970s on homes and very few adjustments are very reliable. I wonder how Fannie is going to do it.
I remember commercial appraisers used to talk about getting cap rates from bottom of a stone monument ;> Maybe we are still looking for that darn piece of stone!!
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Dave Towne on Big Data, Hedonic Regression, etc.
Appraisers………
The new Collateral Underwriter electronic review process developed by FannieMae has many appraisers on edge. This will become the ‘ultimate authority’ or gold standard for reviewing appraisal reports as of January 26, 2015 …. at least as far as FNMA is concerned. Your reports will either ‘pass’ or ‘fail’, depending on many factors. Some of those factors are outside your immediate control.
“Big Data” is one giant pile of stuff that is being put into the CU pot, stirred together like a stew. Except there is no master chef involved that ‘we’ can interact with. Instead we have a bunch of secret sous chefs each contributing a chunk of meat, a bit of spice, some chopped carrots, and a few potatoes. None of them, or us, really knows the actual CU recipe, because part of what’s in the stew is a ‘model’ of something unknown. But some of that Big Data in the CU stew could be yours … or it might be data provided by your peer appraisers who work in your area – that your reports will be compared against. Not too tasty you say? Just add more pepper.
An aspect of this Big Data stew is Census Tract home price analysis, which is compared against your appraised property value. As an exercise, everyone reading this immediately write the neighborhood description using N, S, E & W directionals for the census tract in which your home residence is located. What? You don’t know the boundaries of your census tract? For shame! Some people using the CU stew might think you are deficient because you don’t know price trends in the exact census tract of the appraised property.
Then we have Hedonic Regression. It’s not a bad thing. But it’s becoming the buzz words of our appraisal adjustment process. It’s a ‘background component’ in the CU process, moving farther forward, faster than some might expect.
Bet you didn’t know that the adjustment grid is a form of Hedonic Regression! It’s a way a certain property’s components of value are itemized separately. By using Hedonic Regression, the individual value of the adjustable components can be calculated and plugged into the adjustment grid. In theory, this can lead to a more accurate property value.
The folks at Bradford Software were among the first to begin promoting use of regression techniques by appraisers. In other ways, the other appraisal software companies and some independent developers have been working on individual processes to make “Regression” more palatable and useful to appraisers. Bradford, and the independent developers, have either report software, or separate spreadsheets, that can help calculate property adjustable components, which in turn can lead to a more credible and supportable opinion of value for the appraised property.
The days of “I’ve been an appraiser for 27 years, so I know what this house is worth” are rapidly coming to an end. The Big Data CU stew is overtaking appraising like the snow avalanches that have closed State Highway 20 in north Washington State in the Cascade Mountain range, not far from where I sit in my cozy bathrobe and bunny slippers.
My observation in this process is that appraisers, as a group, are not statisticians by training and are somewhat scared of that term – even though ‘we’ deal with lots of statistics and data. Thus, appraisers don’t have a clear understanding of what “Regression” is, or does. As a result, ‘we’ have been reluctant to embrace this ‘actually old’ technology in modern appraisal reports. And ‘we’ certainly are skittish about FNMA’s soon to be released (to lenders only) Collateral Underwriter which will analyze reports using “Regression.”
Another perspective on this topic is from this blog: http://www.housingwire.com/blogs/1-rewired/post/32165-does-fannie-mae-support-appraisers This one is written by one of the regression spreadsheet developers, currently available to appraisers.
And for info on Hedonic Regression: http://en.wikipedia.org/wiki/Hedonic_regression
My comment: When I first started doing residential lender appraisals in 1986, we used census tract maps to find the code. Later, the codes were available on computers and we did not use maps. However, I found that they were very good for defining neighborhoods. I guess we all forgot about them since few, if any, appraisers look at the maps. I still have my old census tract books.
www.Appraisalport.com poll results
Take the current poll at www.appraisalport.com on c/r fees –
What percentage of your clients offers what you would consider to be customary and reasonable fees for most assignments?
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.
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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.
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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).