Virgina REAB and Portal Petition

[George Hatch]

The point is not how each of us set up our reports, the point is that each of us should be able to set it up in the fashion we think is best to convey the report. The conversion programs are more limiting than our native software, are an add on cost for the appraiser, and increases the time of creating a report, what is there to like? And this is even before the other concerns are brought to the table.

With respect, I think you are arguing a matter of degree. The forms already have limitations and so does every other wordprocessor or typewriter or pad of paper on the planet. You already allow those limitations to intefere with your freedom of expression. How can you draw the line here?

The overarching reporting requirement in SR2 is to "communicate each analysis, opinion and conclusion in a manner that is not misleading." There is also a comment in SR2 that states that:

The form, format and style of a report are functions of the needs of the intended users and appraisers. The substantiative content of a report determines it compliance.

Get that? "...needs of the intended users, as well as those of the appraiser." If a you can accomplish both of those goals within the limitations of a given medium then I don't see how the decision to use that medium would represent a problem with that aspect of SR2.

You wouldn't break out a fresh appraisalware program and send out reports before checking to see that WYSIWYG. If you saw a problem you would tweak your content so that it fit the appraisalware's formatting limitations. You probably wouldn't arbitrarily just stuff it in there and blame the software for any missing information, leastwise I hope not.

How is using a standardized data format any different than that?

 

[Workbox]

Someone should win a medal for the fastest back stroke on record.

 

[TJSum]

"With respect, I think you are arguing a matter of degree." From George Hatch.


Yes, it is. Like I stated, the conversion programs are more limiting than the native software that each one of us uses. We already have limits put upon us by our native software and the conversion programs restricts that even more by the forms that can be converted and the re-arranging of the wording of those forms.

Why take that step backward? Especially when it adds time and cost to the appraiser. From the appraiser's view point, where is the upside to this "improvement"?

Then we embark on the unanswered questions? These go unanswered because we are not allowed to have a peek behind the curtain. We are told "trust us", all of this is just to allow for an automated review process (couldn't they have designed automated reviews from a PDF)?

Why can't the appraiser print out his final version?

Does this conversion program allow for easier changes being made to any one report on the way to the lender?

What does the client actually receive? Is what they think as the true copy the same thing as what the appraiser considers as their true copy?

Does it allow for easier data mining? We all poke fun at the Zaio ZO for creating Zaio's database for them and paying $9,000 for that privilege, but are we doing basically the same thing, the only difference being we are paying $7 per report instead of $9,000 up front?

One of the reason's I thought discussing a national vault was proper for this thread is that many feel that is exactly what AI is trying to accomplish with Appraisal Port and their AI Ready software. Many believe this is the true intent and where all of this is heading. There is many millions of dollars at stake for whoever gets control over a "national database" who can then create the ultimate AVM.

Is this all a way for the individual appraiser to be forced to fall in line and get with the program? Where is the upside to all of this or is it just yet one more part of the downward spiral of this profession? The reason I feel a national "vault" would be better is because the aggenda of those in control, and the procedures involved would be transparent.

 

[Workbox]

TJSum, those "Extreme interest" are more scared of the Vault than anything else. The Signature is one of the "Fronts" of "ONE" who has not yet showed their Avatar on this thread. While the ONE that is posting is and being "Heavily, Coached" is trying to make a case for signatures.

We are here to protect the American Public that many of us signed up for. Those others are here "Because that is the Client wanted" are the cause of this American Mess.

 

[Workbox]

George, I could never and would dare go against your experience, but becuase I have seen and experienced the evidence of what has happened. I will not stand for how they continue to deny what has been happening/Manipulated.

But I still believe their is something wrong with how the end product is being presented, we are just not preview to seeing the end product, and I have been talking to many bankers and ex-bankers about this issue. I hear a quivering in their voice.

 

[George Hatch]

TJ and Al,

These other arguments about inefficiencies and appraiser choice are valid, but they don't involve appraisal standards issues as far as I can see. I believe the same thing applies with respect to the datamining arguments. These are arguments that can and should be made on their own merits, not under the cover of appraisal standards.

The "final versions" of which you guys speak could be considered an appraisal standards issue if you believe that the clients aren't being given the report that you're sending out. Converting the results into salient conclusion cover sheet type summaries and transmitting those to the clients instead of your reports would definitely be a problem in my book. Transmitting them in addition to your reports may be a problem or it may not be; I haven't given that issue enough thought to have an opinion one way or another.

If we want to advocate against datamining - which I believe to be the real issue for many people - then we should be putting that argument forward in a straightforward and direct manner. I don't think that trying to solve that issue by disguising it as a Record Keeping violation is an honest or effective way to go about it.

OTOH, if we have allegations of unavoidable content deletion and editing by these portal companies then we should be addressing those problems directly.

I am in agreement with you that - on a best practices basis - these portal companies should enable appraisers to print out all supplemental materials that contain data from the appraisal report and which are sent to the client. I can't think of any good reason why it would be a problem for anyone to do so, and it just seems like something an appraiser should be allowed to keep in their workfile. Someone might be able to make a good Record Keeping argument arguing otherwise, but I'd have to see that one before i'd give it serious consideration.

Alternately, a state board could require on a statutory basis that their appraisers be given access to those documents. That would work for me.

 

[Marcia Langley]

If we want to advocate against datamining - which I believe to be the real issue for many people - then we should be putting that argument forward in a straightforward and direct manner. I don't think that trying to solve that issue by disguising it as a Record Keeping violation is an honest or effective way to go about it.

George,

I agree. The two seperate issues happened to converge during the Virginia meeting when Mr. Olson said appraisers were responsible for the conversion that they performed on their computer.

I don't necessisarily disagree with that but it begs a few questions.

The conversion that takes place on the appraiser's computer has many aspects and the visual appearance on the appraiser's screen is just one of them.

Per Mr. Olson, the conversion that takes place on the appraiser's computer also imbeds objects that allow for data mining. That is not an aspect of the conversion that is detectable by the appraiser by simply viewing his screen.

Regardless of whether I care about data mining or not, it is clear that the appraiser's own actions have changed what is delivered in ways that the appraiser cannot verify.

You said:

You wouldn't break out a fresh appraisalware program and send out reports before checking to see that WYSIWYG. If you saw a problem you would tweak your content so that it fit the appraisalware's formatting limitations. You probably wouldn't arbitrarily just stuff it in there and blame the software for any missing information, leastwise I hope not.

And I agree. If the only aspect of the conversion were the changes that could be viewed and tweaked and approved by the appraiser prior to transmission that would be all good.

But we know for a fact that more changes are made that we cannot see, verify, or tweak. We just don't know what all those changes are. WYSIWYG only works for the screen-viewable changes.

It would be one thing if appraisers were only held responsible for the screen-visible aspects of the conversion but another thing if the appraiser is held responsible for the non-screen-viewable aspects.

Can the appraiser be held responsible for one non-screen-viewable change (like objects intended for data mining) and not other non-screen-viewable aspects that the appraiser has imbedded in his report?

Can appraiser culpability for the various aspects of one appraisal report that is "transmitted to the client" be segregated into various parts some of which the appraiser is responsible for and some which he is not?

Maybe the answer to that question is yes. But if it is, I think it needs a lot of clarification. If an appraiser is responsible for the entire conversion, then they need a way to test the outcome at the client's end. Otherwise there is no WYSIWYG.

I can do the WYSIWYG test on universally available software but not on client-proprietary software.

 

[George Hatch]

If I understand this question, you're asking if an appraiser would be held responsible for using software that not only force-fits your report into its predetermined format, but also adds software tags and objects, the purposes of which the appraiser has no way of knowing or verifying.

That's a fair question, and I'd never considered it before. Let me see if I can work my way through it and develop an opinion or leaning on it.

Let's say I was working for a fee shop back in 1985 and submitted a typewritten URAR and 2 photocopies, each with "live" signatures on them, to the fee shop. Let's say that I watched the fee shop stamp each of those reports with red ink stamps numbered 1-10 on the cover page prior to sticking the report in the mail. I don't know what those stamps mean but I can see they're being applied in my presence.

Let's take it a step further and say that I applied those stamps according to instructions from the fee shop, even though I don't know what they mean.

Would I be responsible for the "meaning" of those stamps on my report, even though I don't know what they're being used for? Maybe. If those stamps changed my analyses, opinions or conclusions I think I'd definitely have some concerns. If the stamps somehow communicated some sort of personal bias with respect to the borrowers or the subject property in violation of applicable laws or the content of my certs that would be a problem.


OTOH, if the stamps were for routing the report to specified branch, or to flag the report for review or some other administrative task why would I be concerned about that?

I guess the question comes down to whether one believes these software objects, which are stated as being for data handling purposes, are also being used to change content or otherwise contradict the certs in the appraisal or violate some borrower's rights.

Again, if I had some indication that these objects were causing problems for me I'd be upset. Seeing as how I don't understand geek-talk on computer issues I find myself at the mercy of the software providers when they tell me what their software does. As far as I can see what they say they're doing seems to jibe with what I can see, but I can only see a fraction of what goes on behind that monitor screen.

On a practical level I can see what I printed out on my end. I can document what I did in the way of analyses, opinions and conclusions in my workfile. I can't account for what happens to my workproduct between the time I enter the portal's program, use the software to prepare my report for transmittal and send it. All I know it what my report looks like at the moment I sign it, and that I'm being told no changes are being made to the content by the software I'm using.

As far as I can see, the burden of proof is not on me to guarantee that the postman won't attack my report with some whiteout prior to delivering my report across town via snail mail. Same with these electronic portals.

If someone will show me these portals are doing bad things I'll be happy to join in with their opposition. I'm no fan of the corporate fat cats. But so far I've seen no real indication that they've been doing anything other than what they say they've been doing.

I used AppraisalPort for a couple years and to the best of my knowledge none of my files were tampered with at any point in the process. Did they scavenge the data therein? Maybe, but that's not the same problem as altering reports, which as i understand it is the basis for your objections.

Right about now, I guess I'm a lot more concerned about AMCs running rampant, the oversupply of appraisers and what that's doing to the fee structure, and the prospects of a national fee shop selling AVMs disguised as "draft appraisals". Show me something other than a company adding watermarks or printing out salient conclusions cover pages, and I might get as excited as you guys. Other than that, I've got more pressing concerns.

 

[Marcia Langley]

Right about now, I guess I'm a lot more concerned about AMCs running rampant, the oversupply of appraisers and what that's doing to the fee structure, and the prospects of a national fee shop selling AVMs disguised as "draft appraisals". Show me something other than a company adding watermarks or printing out salient conclusions cover pages, and I might get as excited as you guys. Other than that, I've got more pressing concerns.

I agree this issue is not the top priority. Those other issues are much larger. But while the brunt of this conversation thread has been about one system and it's present functionality, there is a larger issue at stake here that will increase in scope and complexity as time goes on. It is a technology-induced quandry that has never been addressed. I think it is appropriate that it should be, by the ASB and by the boards. Appraisers need to know where their responsibility ends.

As far as I can see, the burden of proof is not on me to guarantee that the postman won't attack my report with some whiteout prior to delivering my report across town via snail mail. Same with these electronic portals.

If someone will show me these portals are doing bad things I'll be happy to join in with their opposition. I'm no fan of the corporate fat cats. But so far I've seen no real indication that they've been doing anything other than what they say they've been doing.

I've seen no indication of anything other than what they (currently) say they've been doing either. But then, I wouldn't expect them to report it if they weren't and appraisers have no way to verify. If the changes were made after delivery, appraisers could breathe easy. But appraisers are making these changes themselves and are being held responsible for at least some of them.

I imagine it won't take long in this economic environment for borrowers to become curious as to whether the appraisal copy in their posession matches the appraiser's true copy. If and when it occurs, if a material mismatch is discovered someone will have to decide if those appraiser imbedded objects makes the appraiser culpable.

It would be nice if an appraiser could know in advance exactly where their culpability ended.

 

[Carnivore]

If someone will show me these portals are doing bad things I'll be happy to join in with their opposition. I'm no fan of the corporate fat cats. But so far I've seen no real indication that they've been doing anything other than what they say they've been doing.

Actually Geroge I may just have that silver bullet. I will let you be the first to see what I believe I have discovered about the process. Right now I can actually show you, but I can not prove just yet what the BIG issue actually is!

All I will say at this point is that FNC is complicit in what I have discovered.
If this proves to be true it will be literally earth shattering from a residential appraisers point of view. It may just possibly explain in part how so many loans that went bad were approved to begin with.

I am willing to share with you privately what I have strong suspeicions about!
Let me know how interested you are in hearing more.