3.6 Crunch Time

[djd09]

if the lenders and gse's are going to do what they want and eliminate appraisals...then why parea...which makes taf as corrupt as them

 

[djd09]

oh ok...dw doesn't lie...holier than thou

 

[J Grant]

What denial? The lenders are in it for the money and they will stop using appraisers altogether as soon as they can get away with it.

And yes, some of the decisions they're making very well may turn out poorly for the taxpayers.

You are in denial about the link between GSE influence wrt laws and policies, which are bent and changed to disenfranchise appraisers and appraisals to financially benefit the lenders.

Now, if the lenders were loaning their own money, nobody could have a say in it. But the lenders are lending government taxpayer-backed money, and the GSEs are the gatekeepers to lenders for those loans. The lenders do not have a stated mission of public trust, but the GSE;s have it.

WRT your comment "as soon as they can get away with it" - again, since the lenders are profiting by being allowed to make loans at rates and terms backed by US taxpayers, they should not be "allowed to get away with it "- the GSEs are allowing them to get away with it with waivers which eliminate the appraisal.

Alternate valuation products might substitute for an appraisal, but they do not substitute for the ROLE of the appraiser - the one non-vested interest in the transaction. Becuse of that supposled to be indpenent, non vested intersts gives the appraiser the ability to "kill a deal" - by simply doing hteir job ....the attack on appraisers to marganaiie them has been non stop, and it includes the GSE;s turning a blind eye to the effects of the AMC;s- and if yu want to say it is not the GSE's job to protect the appraiser;s fees.....that is BS becaue appraisers can not function or train the next generain with such sub par fees and the AMC s simply passing the lnder pressure along.

This resulted in a predictable decline of appraisers , then the GSEs and lenders use the declining numbers as an excuse to find alternatives. If you want to close your eyes to the deliberate connection, then so be it.

While never addressing the predation of AMC fees on the appraiser, the GSEs made it their business to protect the RE agents' brokerage fees - when they decided, after the consumer lawsuit wrt RE brokerage fees, the GSEs sent letters to the lenders that the GSEs or lenders need not consider the seller paying a buyer brokerage fee as a covered concession. This in practice neutered the reason for the lawsuit, which was to reduce RE brokerage fees. to borrowers.

The GSEs like to point out the money borrowers saved with appraisal waivers, while their decisions wrt RE broker fees as outside of a covered concession will cost the consumer hundreds of billions more than the relatively smaller amount saved with waiver relief of the appraisal fee.

 

[George Hatch]

100% of that can all be true. So what?

Personally, I think your comment "...bent and changed to disenfranchise appraisers and appraisals..." may inaccurately imply some level of malice toward appraisers. As opposed to apathy or neglect. I strongly doubt the GSEs and the lenders care enough about appraisers to feel any type of way about them. From their perspective we're useful in certain circumstances but not in all circumstances.

AFAICT we don't otherwise matter to them enough to either like or dislike us. We're like...lint. With overhead.

Meanwhile, I still think Santora was right.

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[J Grant]

100% of that can all be true. So what?

Personally, I think your comment "...bent and changed to disenfranchise appraisers and appraisals..." may inaccurately imply some level of malice toward appraisers. As opposed to apathy or neglect. I strongly doubt the GSEs and the lenders care enough about appraisers to feel any type of way about them.

AFAICT we don't matter to them enough to either like or dislike us. We're like...lint. With overhead.

Meanwhile, I still think Santora was right.

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i believe there was a form of malice. (Though I might use a different word, since malice implies personal) I might use the word targeting for elimination, or an agenda - no matter the label, it can include deliberate apathy and neglect.

When each successive change of policy either eliminates the appraiser (waivers ) or cuts them off from half of an assignment (PDR collection) it fits the charge.

Whatever one calls it, - malice, targeting, or agenda...the GSEs are willing to let appraisers be collateral damage. Their verbiage describes appraisals as a point of friction or a speed bump.

Some lenders or loan wholesalers, imo, have more of an internal compass of ethics; they often are the ones who run their own appraisal panels. But they might not be able to withstand the pressure, and thus their use of appraisals will decline as well.

 

[Surf Cat]

When appraisal standards are systematically minimized, alternative valuation products are expanded, and narratives are being pushed that diminish the role of appraisers.....it is reasonable to question whose interests are being advanced.

Wipe Federal laws off the books (an act of Congress) rewrite them so only minimum valuation products are needed.... then there's no argument. But until then....it appears the accountability is moving away from lenders and the GSEs and onto appraisers, borrowers, and the public. That's not innovation... that's a gambler at the craps table who's not worried about losing because everyone else in the casino will be made to pick up the tab.

 

[George Hatch]

"apathy" doesn't imply any superior moral justification than "malice". Either way, the well being of appraisers is irrelevant to their decision making.

 

[George Hatch]

When appraisal standards are systematically minimized, alternative valuation products are expanded, and narratives are being pushed that diminish the role of appraisers.....it is reasonable to question whose interests are being advanced.

Wipe Federal laws off the books (an act of Congress) rewrite them so only minimum valuation products are needed.... then there's no argument. But until then....it appears the accountability is moving away from lenders and the GSEs and onto appraisers, borrowers, and the public. That's not innovation... that's a gambler at the craps table who's not worried about losing because everyone else in the casino will be made to pick up the tab.

USPAP has always been a minimum standard. As as previously noted, has never been changed to enable anything different than what was minimally required of appraisers from the outset.

It's the minimum expectations of the users and their internal policies that have changed. Not what USPAP did or didn't allow appraisers to do.

And here's the thing: even if USPAP and appraiser regulation has changed in the last 30 years and now enables appraisers more latitude as to what SR1/SR2 they're allowed to offer, so what ? "isolated from the principle of change" isn't a thing, particularly when the reference to appraisers keeping up with changes in the marketplace has been explicitly stated in USPAP from the outset. (SR1-1a).

 

[glenn walker]

I don't understand how AMCs can employ appraisers and accept jobs directly. I thought they were supposed to randomly assign appraisals among appraisers and be an intermediary between mortgage companies and the appraiser to avoid the temptation to hit values. Did that law change.

No the law never prohibited AMCs from having staff appraisers and the firewalls are between the appraiser and loan originators. Nothing more or less and lenders can also employ their own staff appraisers if they keep them away or seperated from the loan officers or loan originators.

Finally very few appraisers ever
read the Dodd Frank law and have just continued to repeat what they are hearing from others and even after they know the regulations they argue that was not the intent which is purely conjecture on their part.

 

[J Grant]

"apathy" doesn't imply any superior moral justification than "malice". Either way, the well being of appraisers is irrelevant to their decision making.

But the well-being of lenders and AMCs is clearly relevant to their decision-making. As is creating more risk for the taxpayers.