3.6 Crunch Time

[George Hatch]

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.

The laws and regs which apply to lender operations do not (and have never):

- require the use of an AMC​

- prohibit the use of in-house staff appraisers​

- require appraisals to be assigned at random.​

The laws and regs which apply to AMCs also do not:

- prohibit the use of in-house staff appraisers​

- require appraisals to be assigned at random.​

The requirements of AIR are to isolate the appraisers from the loan origination, including both the external entities you are calling mortgage companies, and the lender's internal business development operations. Engaging fee appraisers via AMC is one way to isolate the appraisers from the sales influence but it isn't the only way. Can contract with individual fee appraisers, can contract with fee shops and appraisal firms, can operate their own in-house appraisal dept except that organizational structure diverts control to credit or underwriting, not loan production.

 

[djd09]

with the mortgage brokers estimating value via waivers with no license or USPAP...it has become a free for all

 

[George Hatch]

The lenders have always been allowed to make at least some loans without an appraisal. Which of course is yet another allowable method to comply with Appraiser independence requirements.

The GSEs have made some changes to their own internal policies, as is their prerogative. That exercise of their prerogative is what appraisers are complaining about. That's what you're angry about.

 

[djd09]

lenders also launder money for drug cartels and epstien...so what's your point

 

[George Hatch]

My point is that the requirements lenders have WRT appraisals only apply when they're using an appraisal. Not when they're choosing a location for an ATM or reporting cash transactions or closing their doors on a workday.

If you're criticizing their unrelated conduct and calling them evil that's fine, but it's also unrelated to appraisal-related laws and regs. It's akin to criticizing a fee appraiser because they cheat on their spouse or take the Lord's name in vain. They might be sinners but those sins are unrelated to their appraisals. As in, irrelevant except to the extent they want to surpass the minimum requirements WRT appraiser engagement.

 

[chad hampton]

GSEs only exist because the US taxpayer bailed them out. They should be on their hands and knees begging for forgiveness for their prior behavior.

Per the former head of the FHFA, expanded use of waivers and hybrids were supposed to be temporary.

 

[J Grant]

The lenders have always been allowed to make at least some loans without an appraisal. Which of course is yet another allowable method to comply with Appraiser independence requirements.

The GSEs have made some changes to their own internal policies, as is their prerogative. That exercise of their prerogative is what appraisers are complaining about. That's what you're angry about.

No kidding. We know what we are angry about.

Their mandate was to modernize appraisals. I fail to see how waivers that ELIMINATE appraisals, and do so to avoid the appraisal regulations target value hitting, only to allow the lender or borrower to invent a target hit value to make the deal work - I fail to see how that protects the public trust. Please don't lecture us with the implication we are big hypocrites for mentioning the public trust since our only concern is fees.

We can comment on how the other side violates their mandate in the quest of profiteering while throwing us under the bus.

The entities use their own internal, using their own controlled parameters, proprietary studies to come out with data that convinces regulators, study after study which always magically, by a tiny margin, supports their next agenda, such as waivers or allowing PDR data collectors to influx into the field.

 

[George Hatch]

GSEs only exist because the US taxpayer bailed them out. They should be on their hands and knees begging for forgiveness for their prior behavior.

Per the former head of the FHFA, expanded use of waivers and hybrids were supposed to be temporary.

That's a perfectly justifiable opinion to hold. But it doesn't speak to how the lenders and GSEs are allowed to operate.

 

[George Hatch]

No kidding. We know what we are angry about.

Their mandate was to modernize appraisals. I fail to see how waivers that ELIMINATE appraisals, and do so to avoid the appraisal regulations target value hitting, only to allow the lender or borrower to invent a target hit value to make the deal work - I fail to see how that protects the public trust. Please don't lecture us with the implication we are big hypocrites for mentioning the public trust since our only concern is fees.

We can comment on how the other side violates their mandate in the quest of profiteering while throwing us under the bus.

The entities use their own internal, using their own controlled parameters, proprietary studies to come out with data that convinces regulators, study after study which always magically, by a tiny margin, supports their next agenda, such as waivers or allowing PDR data collectors to influx into the field.

I repeat the obvious in direct response to the chronic idiocy these two idiots keep posting, because allowing said idiocy to pass without challenge as if they aren't supported by the facts is dishonest. If you're not participating in that idiocy then you shouldn't be acting like the comment is directed to you - because it isn't.

As for how we all believe the lenders SHOULD act, the fact remains that they are allowed to act differently. That's an observation of what we can all see, not an expression of advocacy. Regardless of how those comments make you feel.

 

[J Grant]

My point is that the requirements lenders have WRT appraisals only apply when they're using an appraisal. Not when they're choosing a location for an ATM or reporting cash transactions or closing their doors on a workday.

If you're criticizing their unrelated conduct and calling them evil that's fine, but it's also unrelated to appraisal-related laws and regs. It's akin to criticizing a fee appraiser because they cheat on their spouse or take the Lord's name in vain. They might be sinners but those sins are unrelated to their appraisals. As in, irrelevant except to the extent they want to surpass the minimum requirements WRT appraiser engagement.

Imo, it is absolutely related to appraisal-related laws and regs. They have the ear of regulators and politicians and the rich deep pockets of lenders who can donate to the cause. It is not a coincidence that the laws and policies keep changing to allow the GSE expansion on not using appraisals or appraisers....only to be replaced by riskier or inferior substitutes, like a random person doing a PDR "data collection", or the lender or borrower allowed to invent a property value that hits the target to make a deal work.
'

Fannie even admits the value used in a waiver/value acceptance might not represent the value of the property.