Aloft Appraiser Toolkit

[George Hatch]

One of the first things I learned in my appraiser classes was the residential real estate market is illogical. And perhaps that applies to some appraisers also.

The way I would put it is that SFR/Condo properties serve emotional needs as well as utilitarian needs. What is illogical is for an appraiser or a lender to ignore those motivations and to attribute more to the utilitarian aspects of the property than the market participants are doing.

By contrast, most other property types aren't oriented at satisfying the emotional needs of the buyers and sellers. With the exception of certain office use properties. Nobody brags about the vacant commercial lot they own or the 10,000sf warehouse they own or the mixed use retail/resid'l property they own or the storefront they own. Bragging to the dinner party about the 2-story office building in the downtown area I own isn't going to earn me any status, not like people would be impressed by the nice custom beachfront home or the 10,000sf McMansion.

I personally do not care about a view amenity. BUT as a professional appraiser I know that most people do value that attribute and it's my job to figure out the effect on value. It would be illogical and counterproductive to what I'm trying to do (MV) to arbitrarily assume what that contributory value is. It's an opinion to be developed, not an assumption to make; just like every other attribute.

 

[Mejappz]

One great irony of this back and forth about user requirements vs USPAP is that the requirement for personal inspection was created by one of those GSE "supplemental standards" that some are complaining about in this thread. Yet in other threads there is wailing and gnashing of teeth over the removal of the inspection requirement for hybrids appraisals and desktop appraisals. Still trying to sort out how folks can post both with a straight face.

Despite all the allegations of glad handing, backroom deals, kickbacks, etc., there is ultimately only one thing that really matters - what does the data show related to managing the risk on a mortgage loan?

Ah, that's easy.

Appraisers are licensed and regulated by the states, not by Fannie Mae, Freddie Mac, or any other investor. In Florida, Statute § 475.612 explicitly requires that if any part of the work forming the basis of an appraisal report is completed by someone other than a licensed or certified appraiser, that work must be supervised and approved by the appraiser signing the report.


GSE policies may allow unsupervised third-party property data collectors, but those policies do not override Florida law. Until Florida statutes are changed, appraisers must comply with state-mandated supervision requirements or risk license suspension or disciplinary action.


Whether the GSE considers the appraisal credible for its risk model is irrelevant from a legal standpoint. What matters under state law is whether the appraiser fulfilled their statutory duty, including proper supervision of any third-party contributor to the valuation process.

 

[George Hatch]

"Property attributes are not part of the assignment results. "

As for the legal arguments, expect those arguments to be argued in court by lawyers and settled on the basis of law.

I haven't seen them all, but most states don't use that wording in their statues. My state is one of them.

 

[glenn walker]

Ah, that's easy.

Appraisers are licensed and regulated by the states—not by Fannie Mae, Freddie Mac, or any other investor. In Florida, Statute § 475.612 explicitly requires that if any part of the work forming the basis of an appraisal report is completed by someone other than a licensed or certified appraiser, that work must be supervised and approved by the appraiser signing the report.


GSE policies may allow unsupervised third-party property data collectors, but those policies do not override Florida law. Until Florida statutes are changed, appraisers must comply with state-mandated supervision requirements or risk license suspension or disciplinary action.


Whether the GSE considers the appraisal credible for its risk model is irrelevant from a legal standpoint. What matters under state law is whether the appraiser fulfilled their statutory duty, including proper supervision of any third-party contributor to the valuation process.

So your saying they can't be done in Florida ? Has anyone told Florida?

 

[djd09]

they just wont waive the real risky loans...like marin city

 

[George Hatch]

So your saying they can't be done in Florida ? Has anyone told Florida?

The states are free to add their own additional limitations on their licensees.

 

[Mejappz]

So your saying they can't be done in Florida ? Has anyone told Florida?

No one is saying hybrid or desktop appraisals can’t be done in Florida. They can, but they still have to be done in a way that complies with Florida law. That’s the part people keep skipping over in these discussions.


Florida Statute § 475.612 allows someone who isn’t a licensed appraiser to contribute work to an appraisal, but only if that work is supervised and approved by the appraiser signing the report. So if the appraiser has no idea who collected the data, didn’t train or direct them, and has no way to verify their methods or qualifications, then they really can’t claim to be in compliance, even if Fannie or Freddie says it’s acceptable for their purposes.


That’s the core issue. Just because a GSE accepts a certain product doesn’t mean it meets state law requirements for licensed professionals.


I know there are people on the forum who like to pick and choose which rules or laws they want to follow, depending on whether it fits their preferred narrative. But unless and until the Florida Real Estate Appraisal Board issues new guidance, those are the laws we’re bound by. We may not like them, but we’re still required to follow them if we want to keep our licenses.


So no, the question isn’t whether hybrids or desktops are legal in Florida. The question is, can they be completed in a manner that complies with Florida’s supervision requirements? If the answer is no, then the format isn’t the problem. It’s how the assignment is being executed.

 

[Mejappz]

And if anyone believes the state boards actually enforce these laws and statutes, just take a quick look through the forum to see for yourself.

 

[Surf Cat]

Today the apprasers role in mitigating loan risk is almost zero.

Go team eliminate the appraiser!

I wonder if all those cushy gigs at TAF, ASB, and State appraisal bureaus would agree with your assessment. After all, we need to ramp up hybrids and PAREA grads to enhance their investment portfolios.

 

[Joe Flacco]

You should file a lawsuit and see what happens.