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I Came in Low. My obligations under Dodd Frank?

Discussion in 'Fannie Mae, Freddie Mac, USPAP' started by JSmith43, May 2, 2012.

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  1. BRCJR

    BRCJR Senior Member

    9
    Sep 20, 2005
    Professional Status:
    Licensed Appraiser
    State:
    Virginia
    You are assuming too much. My question was no more detailed than the OP was in presenting his concern.

    I sure am glad he did not direct me to turn in every USPAP violation regarding previous services and exposure time I have discovered this year.

    We try to use common sense and expect people we do business with to try and do the same.
     
  2. BRCJR

    BRCJR Senior Member

    9
    Sep 20, 2005
    Professional Status:
    Licensed Appraiser
    State:
    Virginia
    What is the violation the OP was exposed to?
     
  3. timd354

    timd354 Elite Member

    97
    Jan 11, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    Maryland
    Compliance officers, just like appraisers, vary widely. I know some compliance officers who would attempt to get the LO and the processor terminated in this situation, especially if they were repeated offenders. There are quite a few lenders that have internal policies prohibiting LOs from having any contact with the appraiser.
     
  4. rcsone

    rcsone Senior Member

    0
    May 26, 2007
    Professional Status:
    Certified Residential Appraiser
    State:
    Oklahoma
    ....more laws or regs to unenforce.....best to all........rs
     
  5. BRCJR

    BRCJR Senior Member

    9
    Sep 20, 2005
    Professional Status:
    Licensed Appraiser
    State:
    Virginia
    Additional terms to the OP would also change my mind. I make my comments based upon the OP and no subjectivity added.

    There is no reference to it being a repeat offender or what the lender policy is.
    A different situation would also create a different position on my part, most likely.

    I am replying only on what is posted and not on other possibilities.
     
  6. Ca Ar Independent

    Ca Ar Independent Senior Member

    2
    Sep 24, 2011
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    My recent experience involved being contacted directly by the LO (I didn't know she was the LO at the time, new Bank, lots of people involved with processing) who asked me to "reconsider" the value. She sent over the "other appraisal". I reminded myself that I was not hired to review this POS obvious "value push" piece of work, but to merely address her concerns. I looked a the 3 comps she suggested, addressed the other appraisals mathematical errors which only strengthened my well supported value. She went away and I thought this was over and done, while slightly surprised that someone from inside the bank would be operating this way. Anyway, a couple of weeks later I get the EXACT SAME request from someone else in the bank (seems she had escalated this to a formal request for consideration). I forwarded the original email string (with original request and my response) explaining politely that I had "already been contacted by someone at the bank" regarding this and here is my analysis and response. Apparently this put her on front street since the appraisal review department did not know she had already asked me about this. I'm guessing (hoping) I won't hear from her again. The compliance department then called me and asked me to "help them" police their employees by verifying who may be contacting me in the future. He indicated it would be my responsibility to be sure that I was not talking to loan origination. I am supposed to check email signatures (and apparently ask any phone caller) what area of the bank they work for. Had a similar thing happen recently with a different bank, with the approval department nervously phoning asking if I could "get a little more" out of the appraisal.
     
  7. JamesRockford

    JamesRockford Senior Member

    0
    Oct 22, 2010
    Professional Status:
    Certified General Appraiser
    State:
    California
    Not assuming anything, just responding to your post regarding your CO's comments on the OP's situation here.

    And based on the OP's later posts, it appears your CO was incorrect in his "analysis" and this WAS undue value influence and therefore a violation of Dodd-Frank that SHOULD be reported.

    All you have to do is read the post above this one.
     
  8. BRCJR

    BRCJR Senior Member

    9
    Sep 20, 2005
    Professional Status:
    Licensed Appraiser
    State:
    Virginia
    The additional posts did not exist when I posed my question to the CO.

    Your positon is akin to holding me responsible for a sale that ocurred after the effective date. More information has come forth since the first post. My comments were based upon the first post only. I read nothing in the first post that rises to the level of unlawful.

    Keep things in order and post accordingly, otherwise one can twist comments.
     
  9. Webbed Feet

    Webbed Feet Elite Member

    22
    Feb 11, 2005
    Professional Status:
    Certified Residential Appraiser
    I like the above post.

    I'm tired of reading posts about an appraiser that did a good job "coming in low." For once, I'd like to read a post from an appraiser accusing him or herself of "Coming in credible."
     
    Last edited: May 5, 2012
  10. Webbed Feet

    Webbed Feet Elite Member

    22
    Feb 11, 2005
    Professional Status:
    Certified Residential Appraiser
    Someday, the majority of this trade will finally decide that ethics requires they police their own by filing board complaints whenever they are sent "POS" appraisal reports. Until then, the extreme minority will carry the burden of it for everyone else.
     
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