GSE Waiver & Data Collection Data

[George Hatch]

Because, state legislatures make appraisal laws and appraisal boards enforce those laws. I’m interested into why you think the users of appraisal services should be the ones dictating laws and regulations?

I mean, I guess that’s how we do things in this country, we let oil companies write energy laws, and we let the abusers of real estate right real estate laws. I’m just saying it’s not the moral and ethical thing to do. But you always argue on behalf of the unethical so I get it.

And if the GsEs and their breakfast club want laws changed, they should go through the proper channels to change them. But that’s harder than intimidation and threats of lawsuits.

Can you elaborate on

I’m interested into why you think the users of appraisal services should be the ones dictating laws and regulations?​

Firstly - I never said any such thing. Never thought it, never implied it, never said it, don't support it, don't want it. You gots to evolve past the JGrant School of creative reimagination for kids who don't read good and stuff.

Secondly - In what way do you think the users of appraisal services dictate the laws and regulations? I mean other than (what you constantly complain about) show up at a meeting and tell the board they'll go to court to protect their legal rights via due process if it comes to that. If the board was on your case for some reason I would expect you to do the same. After all, this here is still America and the licensed parties have their respective rights under the law.

Thirdly - Use your words instead of just doing that hit-n-run thing you always do.

 

[Tim Hicks (Texas)]

Danny wants to boast that the PDR does a better job of inspecting that traditional appraisers. That is based on their data. However, that does not alleviate the poor job of evaluation by many poorly trained or unscrupulous appraisers. I still see to this day appraisals that somehow passed all the underwriting with poorly supported adjustments, made up adjustments and adjustments that real data does not support to hit the sales price. And the other way around too. Poorly applied adjustments that data does not support below the sales price.

That would appear to be a more important aspect than the inspection of the property. Mabe that is coming next, replace the appraisers on the evaluation part too.

 

[J Grant]

The only way to see if a PDC inspection vs the appraiser inspection results in a different "As Repaired" , would be to send out an appraiser and a PDC collector to both inspect the same house, and they will never pay for that extra step to happen.

 

[Terrel L. Shields]

anything they actually have to do more research and analysis at their desk in order to bring themselves up to speed.

Then we should get a premium fee, not a lesser one, yet no one is proposing the hybrid EXCEPT TO CUT THE COST AND TIME TO DO A REPORT. NO ONE...

In what way do you think the users of appraisal services dictate the laws and regulations?

Then who is pushing for these less-than-appraisal appraisals?

I still see to this day appraisals that somehow passed all the underwriting with poorly supported adjustments, made up adjustments and adjustments that real data does not support to hit the sales price.

Don't you think that a large part of the problem is not sufficient time spent in analysis, and somewhat less in inspection? And the reason the appraiser is rushing is not because they are too busy, but because the fee is so low, they are not making C-Store wages if they don't generate the report in 3 hours or so. It's a rare property I can devote any less than 8 hours to it. But I am not doing that for $150 bifurcated report.

Where is the time savings? I have to go thru the data collectors information, I have to vet its credibility, verify the facts I can, and I have to then transfer the data to the report and do my analysis. What happens when the data collector says there are 3 bedrooms and the MLS says 4? What happens when the MLS says it has a microwave and dishwasher but the data collector doesn't mention a microwave? Will it show in the photos? Will you have to then explain why the DC is wrong? Does it reflect upon the credibility of the collector?

 

[George Hatch]

The sheer stupidity of this allegation is really annoying

why you think the users of appraisal services should be the ones dictating laws and regulations​

It is completely illogical to allege that these AMCs and users are dictating the laws/regs when none of the laws/regs relating to these issues have been changed. Equally illogical to equate a regulated party (a appraiser licensee or a regulated AMC) providing their opinion and stating their case to a state board with "dictating laws and regulations" when those state boards are not the party that legislates state law into existence in the first place.

Appraisal board is part of that state's Executive Branch, not the Legislative Branch. Duh.

 

[J Grant]

Appraisers were even willing to compromise. We said many times that we will consider accepting an appraisal inspection from another certified appraiser - we can talk about that. And we would also consider a home inspection report as a substitute for doing the field appraisal work. Both of those ideas were thrown in the trash. I will let you guys figure out the reason why

The breakfast club wants their 1 million out of work real estate agents doing these for cheap.

Yes, they wanted non licensed non-appraisers to inspect for CDC because a huge # of RE agents, and others would keep fees for teh PDC collection low, vs a more limited number of licensed appraisers. Most conclude that the PDC is only profitable and worth it on the admin side to larger AMC's or a few lenders who run large in-house panels - in both cases, likely using staff appraisers. I hope it stays that way.

A danger in seeing PDC 's reach a larger volume is that the appraisers doing the analysis side at a desk could take on work outside their geo-familiar area. Sounds like increased risk -- a non appraiser doing a rote collection of data and then pair it with an appraiser who lives two hundred miles away and never set foot in the area.

 

[glenn walker]

Doesn't matter that the technology is improved- the appraiser was still denied the first-hand inspection and added observation first-hand.

Since most buyers and sellers and RE agents have been inside the property.with a thrid party PDC collection, the appraiser is now less well informed then the others in a transaction.

They always have been the least informed party in a transaction. Largely because many were mentored to be isolated. The biggest complaint we had from borrowers was the appraiser had spent less than 10 minutes inspecting their homes some bragged it was a run through inspection.

THE APPRAISERS DID ALMOST NO Real inspections on conventionals and many said outside of measuring it was a waste of time. The same ones loved Covid Exteriors because it paid the same or more than a full.

Inspections only became an issue when appraisers found out someone else was going to do it and suddenly it became a issue because we are closer to getting to the end of the traditional old way it's been done.

 

[J Grant]

The sheer stupidity of this allegation is really annoying

why you think the users of appraisal services should be the ones dictating laws and regulations​

It is completely illogical to allege that these AMCs and users are dictating the laws/regs when none of the laws/regs relating to these issues have been changed. Equally illogical to equate a regulated party (a appraiser licensee or a regulated AMC) providing their opinion and stating their case to a state board with "dictating laws and regulations" when those state boards are not the party that legislates state law into existence in the first place.

Appraisal board is part of that state's Executive Branch, not the Legislative Branch. Duh.

Okay, change that to the laws have not been changed, but new products were developed that profit AMC's said products, occupying a grey area on the legal or credible scale -

The WAIVER is such a product- a valuation that is not an appraisal, developed because it is not subject to the regulations of appraisals and thus can have a loan officer estimate the value , or the sale price be the property value (as long as the value falls in the GSE AVM range )

The other product is the expansion of the hybrid into 1004 origination loan use , and the flood of non-licensed non-appraisers to do the inspection portion, it entails. To skirt the USPAP grey zone of when an inspection is part of appraisal practice, it is called a data collection; the Data collector provides no opinions.

 

[J Grant]

They always have been the least informed party in a transaction. Largely because many were mentored to be isolated. The biggest complaint we had from borrowers was the appraiser had spent less than 10 minutes inspecting their homes some bragged it was a run through inspection.

THE APPRAISERS DID ALMOST NO Real inspections on conventionals and many said outside of measuring it was a waste of time. The same ones loved Covid Exteriors because it paid the same or more than a full.

Inspections only became an issue when appraisers found out someone else was going to do it and suddenly it became a issue because we are closer to getting to the end of the traditional old way it's been done.

Total BS - Appraisers are very well informed -and my comment wrt the appraiser is less well informed in a hybrid it is meant as just what I said, the appraiser has not set foot on the property, but others in the transaction have typically been in the property ( the buyer, the seller, the RE agent )

You have some lending BG or family company involvement, you never fully disclose which colors your answers - pass-

 

[George Hatch]

Then we should get a premium fee, not a lesser one, yet no one is proposing the hybrid EXCEPT TO CUT THE COST AND TIME TO DO A REPORT. NO ONE...

Then who is pushing for these less-than-appraisal appraisals?


Don't you think that a large part of the problem is not sufficient time spent in analysis, and somewhat less in inspection? And the reason the appraiser is rushing is not because they are too busy, but because the fee is so low, they are not making C-Store wages if they don't generate the report in 3 hours or so. It's a rare property I can devote any less than 8 hours to it. But I am not doing that for $150 bifurcated report.

Where is the time savings? I have to go thru the data collectors information, I have to vet its credibility, verify the facts I can, and I have to then transfer the data to the report and do my analysis. What happens when the data collector says there are 3 bedrooms and the MLS says 4? What happens when the MLS says it has a microwave and dishwasher but the data collector doesn't mention a microwave? Will it show in the photos? Will you have to then explain why the DC is wrong? Does it reflect upon the credibility of the collector?

These are excellent rebuttals to arguments I never actually made as such.

I never said appraisers should get paid less for their hours​

I never equated what the lenders and GSEs hold as their internal policies with being the law of the land. You're the one doing that.​

I never said appraisers will spend less time on their research/analysis - I actually said the opposite​

Fun fact, I don't drive all of my comps in most of my assignments because most of my clients don't require it. I am completely in spec in those assignments because my users' expectations for that element are different (in some assignments) than the GSE expectations. User-driven does not mean the same thing as does "required by law" or "required by USPAP". Some similarities between them all, some differences between them all.

Heck, I'm writing a desktop appraisal today for an industrial zoned lot with a suburban location - no physical inspection of the subject and no PDR. Because I have that latitude under USPAP and the licensing laws. I am not prohibited from doing so. Moreover, my client has engaged me on this basis knowing in advance of the additional assumptions and limitations of doing it this way. I've got another no-look appraisal assignment in my backlog for a mixed use property, although I'll probably cruise by just for the heck of it because I've got a couple multi-families to do in that general direction - I'll do the exterior at my discretion, not because it's actually part of my assignment.

Render unto your users those requirements which are theirs' alone.