Virgina REAB and Portal Petition

[Pamela Crowley (Florida)]

Thank you Maverick.

 

[McPheeters]

Dear DWiley,

I visited http://www.sfrep.com/company/ . Since you know the owner would he or you help me in understanding how I can retain or save that which I send through the OADI uploader? These are the steps I have attempted:

When the OADI report reviewer launched to show me the new version of the report, there is no way to print the report. There is only a button that enables the user to SAVE the report. But, only allows the user to save the report in one file format, "ENV"? file format. I did that and tried to open it as a text file and other than some header information, the rest of the file is jibberish, just like if you opened any binary file in a text editor.

I went back to the viewer to open the file I saved on my desktop and it wouldn't open it again. I view the new "version" of the report one time, then it's either deliver it or cancel it. But, the only way to "keep" a copy I agreed to deliver to the lender is if you save it to the ENV file format, and then I can't even go back and view that file with the OADI viewer.

It's the process I just walked through, at this point there is no way for me to print a copy of all the material transmitted so I can have in hand what is transmitted to the lender.

I think something was said in previous posts about being sure to view what is being sent before sending. But, I would appreciate the benefit and capacity to retain that which is/was sent?

Respectfully,

Maverick

Thank you Mav for this post. I would like to know how to retain what was sent as well, particularly since the USPAP require me to do so......

 

[Pamela Crowley (Florida)]

Anybody here that knows about the First American / FNC partnership want to explain how the AMC appraisers provide their permission to the AMCs to convert/alter their appraisal reports, for the AMC to apply the appraisers previously 'lifted' '.jpg' signature to the altered appraisal reports, and deliver these altered appraisal reports to both the clients and FNC? When and where do appraisers give the various AMCs permission to do this while taking full responsibility for those altered reports? While I'm at it, why are these altered appraisal reports being delivered unlocked? Do you think a loan officer and/or processor and/or anybody else that can access the appraisal reports could make any changes they wanted to those unlocked appraisal reports?

 

[Carnivore]

Thank you Mav for this post. I would like to know how to retain what was sent as well, particularly since the USPAP require me to do so......

This is really the big issue. Ken and Danny keep kickin up dust to obscure this problem.

Pay Attention. Especially YOU Ken!

All I and many other apprasers want at this time is to be able to:

1. save the FNC file(yes we can do it now)

2. Open the file back up at a later date(no we can not do this now)

3. Print the actual conversion that is sent to the lender(no we can not do that now)!

What is so hard about that? Why is that so unreasonable?

Correct me if I am wrong, but I am sure I read that as a requirement in USPAP!

 

[Workbox]

Has any techies called SFREP about this issue? Maybe they have an insight on how to print.

 

[Larboard]

And once they had it, whether they got it from the appraiser or the vault, they could do what they want. The vault would not change that. It would only provide an "authenticated" copy, which is what digital signatures already do.

So, the vault approach would provide an "authenticated" copy until whatever time in the future it was deleted from the vault.

The digital signature approach would provide verification against an "authenticated" copy only as far as the first recipient. That recipient could create a new file with a new digital signature, and other changes, to send to the next recipient as a secure file.

Is that right?

 

[Marcia Langley]

Maverick,

Thanks for that detailed example of what you were able to see and do with your uploaded file.

Your experience seems to be identical to Carnivore's. His appraisal software is AlaMode. What is yours?

 

[Jonsey]

Do you think a loan officer and/or processor and/or anybody else that can access the appraisal reports could make any changes they wanted to those unlocked appraisal reports?

Yes. I believe so, the probability is high. Who would dare to say with certainty that a processor would not take it upon themselves to change a report for reasons that may never occur to us.....ie. to expedite the processing of a file when the appraiser couldn't be reached (finals, repairs, stips, etc) or when an appraiser refused to redress value issues that affect lenders LO's bottom line commission.

It would be so interesting to hear from processors, underwriters who've worked for AMCs, especially those who utilize proprietary portals. It is makes more sense, is more convenient for these entities to go through their long lists of appraisers after a file has been tampered with (just move on to the next appraiser - none will be the wiser) than it is to obtain new large lender clients. Appease the client - thousands of Appraisers are on these lists submitting reports while utilizing these portals = a dime a dozen - when compared to what clients are paying. Employee salaries.

 

[DWiley]

So, the vault approach would provide an "authenticated" copy until whatever time in the future it was deleted from the vault.

The digital signature approach would provide verification against an "authenticated" copy only as far as the first recipient. That recipient could create a new file with a new digital signature, and other changes, to send to the next recipient as a secure file.

The digital signature would apply to multple recipients. There is nothing restricting it to just the first recipient.

Good digital signatures not only verify the security of the report, they also verify the authenticity of the author via hardware. This can be done using a "token," usually a USB fob. The token must be in the computer in order to apply the signature.

Someone could change a report, but the digital signature would alert the reader that the file was altered. Someone might apply another digital signature, but they could not apply yours.

Anyone can Google "digital signature" or "PKI Signature" and see that this is widely used technology.

 

[Ken B]

This is really the big issue. Ken and Danny keep kickin up dust to obscure this problem.

Pay Attention. Especially YOU Ken!

All I and many other apprasers want at this time is to be able to:

1. save the FNC file(yes we can do it now)

2. Open the file back up at a later date(no we can not do this now)

3. Print the actual conversion that is sent to the lender(no we can not do that now)!

What is so hard about that? Why is that so unreasonable?

Correct me if I am wrong, but I am sure I read that as a requirement in USPAP!

Andrew,

I believe I am on the record stating that it would be preferable to make a hardcopy print out of the ENV file or any other file that is required for transmittal to a distant party. However, I don't think that USPAP actually requires hardcopy print outs. If someone would like to identify the section of USPAP that requires a hardcopy printout of a report, I will happily change my mind about that. To my knowledge, USPAP merely requires that a true copy of the report be retained in the workfile. The workfile is not necessarily something you can pull out of a drawer and touch. If the State Boards want to make a rule that a hardcopy printout of reports as delivered to a third party be retained or available for review, that is their right. I think any State Board that wants to make a rule that a certain electronic portal must be approved prior to use by an appraiser is totally off the mark with regards to their authority and responsibility. But that is my opinion.

Any CG thinking this is a residential problem better think again. I believe RIMS qualifies as an electronic portal.

However, if a hardcopy print out of the ENV file is truly the primary concern, are you saying a software upgrade to allow this action would alleviate your issues with the various conversion programs used for electronic delivery of an appraisal report?

If so, I think that could be a very easy fix.

And for the people that don't like me "kicking up dust", I would think that someone like me bringing attention to the weaknessess and inconsistencies with the proposals made by other parties would be preferable to someone quietly taking advantage of those weaknesses for ill gain.

Best regards to all.