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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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

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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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Fannie's Appraiser Quality Monitoring(AQM) FAQs July 2014(Opens in a new browser tab)