Fannie Mae Aqm List

[DWiley]

I don't think enough licenses are being revoked by licensing boards...

My observation is that is highly variable by state. I can cite extreme examples on both sides of the coin. I have a case where an appraiser's license was suspended for three months with the only citation being the failure to include a prior service comment in the report (even though there was clear evidence that the client was aware of the prior service, and had even selected the appraiser due to the prior service). So, in that case there was a suspension for a reporting error. I also have a case where a certified appraiser with over 20 years of experience sent someone else out to inspect the home, and admitted it, yet the state only issued an informal counseling letter. Examples like these are the reason that we read the details of all disciplinary actions and do not look only at the final sanction.

 

[djd09]

Does Fannie Mae’s appraiser monitoring alter lenders’ obligations related to appraisers and appraisal quality?
No. Lenders remain directly responsible for the selection and management of appraisers and appraisal quality, as described in the Selling Guide
. Appraiser monitoring augments lenders’ controls but does not replace or alter lenders’ obligations.
https://www.fanniemae.com/content/FAQ/appraiser-quality-monitoring-faqs.pdf

Where is the list of the lenders of the 25 appraisers. According to their FAQ the lender is responsible for appraisal quality.

 

[J Grant]

Way to go Mich, denigrate your fellow appraisers, instead of considering they/we might have something to say. But that's consistent with your approach, which is to call other appraisers idiots, and side with RE agents being able to block access to appraisers from properties. I presume these tactics gets you business in your area.

Back to the topic, my point is that fees are to be, by LAW, be determined by C and R. Something which MichCG is in denial about, as he refuses to acknowledge it. He also refuses to acknowledge that AMC retaining portion of fee has any result fees. Supposedly the law does ot in what fees end up at to appraisers.

I realize that supply and demand can result in the fees that surveys rely on to establish C and R.

Which brings it to the problem is that the very actions of the AMC's impact the fees which establish C and R. An AMC controls which appraisers they give orders to, and simply withholds work from any appraiser charging over X$. They do this unless dire circumstances such as a busy period in a few regions making it not possible, at which point they lobby for a change of regulations due to a supposed "shortage"

The AMC controls which appraisers gets their appraisal orders in any given area they operate in. . Thus, the actions they take in appraiser selection can drive down fees, it is not simple supply/demand, it is linked to their policies and participation. If they refuse to assign work to any appraiser who charges over X $, then the fact that a number of appraisals are done below X$ can become the standard for C and R in that region.

Appraisals for GSE lending are supposed to serve the mission of USPAP and the public trust, not be the "same" as any business which does not have that mission..

Because of that, the clients have a mandated obligation of due diligence in appraiser selection. The clients/their AMC agents are supposed to award work for other metrics besides low fees, which they often fail to do.How can it be mere coincidence when 90% of their work in a region ends up done by only those appraisers who charge below X $.

I Can go on, but some for their own reasons will continue to deny the reality of contributing factors to low fees other than simple supply and demand, who fail to recognize the law and the mission of appraisals which does not make it "like any other business responding to supply and demand" for GSE work..

The trend of the future will be hire as much staff appraisers as possible, so negotiate a good salary for yourselves.

 

[Joe Flacco]

My observation is that is highly variable by state. I can cite extreme examples on both sides of the coin. I have a case where an appraiser's license was suspended for three months with the only citation being the failure to include a prior service comment in the report (even though there was clear evidence that the client was aware of the prior service, and had even selected the appraiser due to the prior service). So, in that case there was a suspension for a reporting error. I also have a case where a certified appraiser with over 20 years of experience sent someone else out to inspect the home, and admitted it, yet the state only issued an informal counseling letter. Examples like these are the reason that we read the details of all disciplinary actions and do not look only at the final sanction.

Nobody is serious about USPAP compliance. Licensing boards, chief appraisers, firm owners, and a large percentage of appraisers. USPAP is not some high level stuff. It is the basics.

 

[J Grant]

Way to go Mich, denigrate your fellow appraisers, instead of considering they/we might have something to say. But that's consistent with your approach, which is to continually call other appraisers idiots, and side with the idea of RE agents being able to block access to appraisers from properties.

Back to the topic, my point is that fees are by LAW, be determined by C and R. Something which MichCG is in denial about/ refuses to acknowledge. He also refuses to acknowledge that AMC retaining portion of fee has an impact on fees. Supply and demand was present pre HVCC, yet prior to profit retention by third parties, fees did not go down in slow times, the fees stayed the same, the volume of work went down. .

The real reason supply and demand is of concern is that AMC's can use their supply of work and at what fees they award it, to result in lower fees becoming more common in an area and thus a standard for C and R. Since consumers pay the appraisal fee, if they could not profit on the split, they would have NO incentive to drive down fees lower to a C and R lower amount. But the reality is they DO have this incentive since their profit is in the split. It is this conflict of interest that needs to be corrected, and I recall Danny himself said cost plus would be a better system.

Which brings it to the problem is that due to profit incentive form the split, the actions of the AMC's regarding which appraise they assign work to serves t impact the fees which establish C and R.

An AMC controls which appraisers they give orders to, and simply withholds work from any appraiser charging over X$. They do that all the time whenever possible, only in recent extreme busy times in certain areas they are getting push back on that ( thus complaining to AF and regulators about an appraiser shortage)

The AMC controls who gets what share, and who gets none, of the appraisal work in areas they operate in. Thus, the actions they take in appraiser selection can drive down fees, i

Appraisals for GSE lending are supposed to serve the mission of USPAP and the public trust, not be the "same" as any business which does not have that mission of public trust.

Because of that, the clients have a mandated obligation of due diligence in appraiser selection. The clients/their AMC agents are supposed to award work for other metrics besides low fees, which they often fail to do.How can it be mere coincidence when 90% of their work in a region ends up done by only those appraisers who charge below X $.

I Can go on, but some for their own reasons will continue to deny the reality of contributing factors to low fees other than simple supply and demand, who fail to recognize the law and the mission of appraisals which does not make it "like any other business responding to supply and demand" for GSE work..

 

[Eli]

You do know that anything you say to these two will never sink in? If you need someone to talk to about economics and reality my dog would be more receptive to reality.

Nobody ever said supply and demand don't apply to a market. I haven't heard it. How do you measure forced demand? Some lenders realize risk associated with collateral value. Some could care less. The reasons some want or need (demand) an appraisal is because the government knows what is best for the public. Real estate fraud is alive and well. Some lenders truly care about the public and have true demand. As a side note, state govt is losing tax dollars to AMC's on in-state appraisal fees and that won't last.

 

[J Grant]

My observation is that is highly variable by state. I can cite extreme examples on both sides of the coin. I have a case where an appraiser's license was suspended for three months with the only citation being the failure to include a prior service comment in the report (even though there was clear evidence that the client was aware of the prior service, and had even selected the appraiser due to the prior service). So, in that case there was a suspension for a reporting error. I also have a case where a certified appraiser with over 20 years of experience sent someone else out to inspect the home, and admitted it, yet the state only issued an informal counseling letter. Examples like these are the reason that we read the details of all disciplinary actions and do not look only at the final sanction.

That's good to hear and makes sense, board actions may not always be related to overall competence an ethics.

 

[DWiley]

Nobody is serious about USPAP compliance. Licensing boards, chief appraisers, firm owners, and a large percentage of appraisers. USPAP is not some high level stuff. It is the basics.

I would not go so far as to say "nobody" - but, I agree that it is far from enough I know at least a few chief appraisers who take it VERY seriously.

 

[Eli]

Regulators should be doing what AMC's do.

 

[Eli]

Way to go Mich, denigrate your fellow appraisers, instead of considering they/we might have something to say. But that's consistent with your approach, which is to continually call other appraisers idiots, and side with the idea of RE agents being able to block access to appraisers from properties.

Back to the topic, my point is that fees are by LAW, be determined by C and R. Something which MichCG is in denial about/ refuses to acknowledge. He also refuses to acknowledge that AMC retaining portion of fee has an impact on fees. Supply and demand was present pre HVCC, yet prior to profit retention by third parties, fees did not go down in slow times, the fees stayed the same, the volume of work went down. .

The real reason supply and demand is of concern is that AMC's can use their supply of work and at what fees they award it, to result in lower fees becoming more common in an area and thus a standard for C and R. Since consumers pay the appraisal fee, if they could not profit on the split, they would have NO incentive to drive down fees lower to a C and R lower amount. But the reality is they DO have this incentive since their profit is in the split. It is this conflict of interest that needs to be corrected, and I recall Danny himself said cost plus would be a better system.

Which brings it to the problem is that due to profit incentive form the split, the actions of the AMC's regarding which appraise they assign work to serves t impact the fees which establish C and R.

An AMC controls which appraisers they give orders to, and simply withholds work from any appraiser charging over X$. They do that all the time whenever possible, only in recent extreme busy times in certain areas they are getting push back on that ( thus complaining to AF and regulators about an appraiser shortage)

The AMC controls who gets what share, and who gets none, of the appraisal work in areas they operate in. Thus, the actions they take in appraiser selection can drive down fees, i

Appraisals for GSE lending are supposed to serve the mission of USPAP and the public trust, not be the "same" as any business which does not have that mission of public trust.

Because of that, the clients have a mandated obligation of due diligence in appraiser selection. The clients/their AMC agents are supposed to award work for other metrics besides low fees, which they often fail to do.How can it be mere coincidence when 90% of their work in a region ends up done by only those appraisers who charge below X $.

I Can go on, but some for their own reasons will continue to deny the reality of contributing factors to low fees other than simple supply and demand, who fail to recognize the law and the mission of appraisals which does not make it "like any other business responding to supply and demand" for GSE work..

That is pretty good JG. You acknowledge other market forces other than supply and demand. I thought that was appraisal 101. Some better get used to C&R. They prolly better get used to a state taxing an AMC on their cut too.