Appraisal Independency Requirements-Who do you report it to?

[TerryRohrer]

So, they employed me twice, I called the Realtor to set the appointment up, and both times in a day they were canceled and given to someone else on their list. There isn't any conflict of interest. More likely the owner who is also a Realtor talked the lender into side stepping me and going with a different appraiser.

Have you done any work where any of the parties were involved before? This is usually the sequence of events when you have appraised something for less than the contract price or owners opinion of value in the past. When you contact the realtor/gatekeeper, they relay to the lender or AMC that you have a conflict of interest (lenders and realtors find being honest and unbiased as conflicts of interest...theirs), the lender cancels the assignment to you and selects a play along to get along number hitter.

 

[apprtech]

Ok, that is a new detail. I still don't see the violation. What if the lender pulled the orders because this was part of a larger portfolio of properties and they wanted all their orders to go to the same appraiser?

Read AIR and tell me the violation.

https://singlefamily.fanniemae.com/media/4711/display

IV. Independent Party Engagement A. The Seller must separate its sales and Mortgage production functions from its appraisal functions. An agent or employee of the Seller involved in the Seller’s sales or Mortgage production function must have no involvement whatsoever in the operations of the Seller’s appraisal functions. If absolute lines of independence between the Seller’s collateral valuation process and its Mortgage production process cannot be achieved because of the Seller’s small size and limited staff, the Seller must clearly demonstrate within its written policies that it has prudent safeguards in place to isolate its collateral valuation process from influence or interference by its Mortgage production process.

The lender has not put safeguards in place and is allowing the Realtor, seller, or Buyer to dictate not using a specific appraiser. Which is in essence picking their own appraiser.

 

[alebrewer]

The lender has not put safeguards in place and is allowing the Realtor, seller, or Buyer to dictate not using a specific appraiser. Which is in essence picking their own appraiser.

Those dots are even more difficult to connect. It's one thing to call out a conflict of interest and get the appraisal reassigned. It's quite another when the Realtor tells the lender who to use.

 

[apprtech]

Have you done any work where any of the parties were involved before? This is usually the sequence of events when you have appraised something for less than the contract price or owners opinion of value in the past. When you contact the realtor/gatekeeper, they relay to the lender or AMC that you have a conflict of interest (lenders and realtors find being hones and unbiased as conflicts of interest...theirs), the lender cancels the assignment to you and selects a play along to get along number hitter.

I have appraised one property for the seller which is also a Realtor. It was a situation where the appraisal came back substantially lower. When I asked him for his CMA, he sent me sales from two counties away when there were ample sales in the subject county, they just did not meet his value he was trying to obtain.

 

[Mejappz]

I was told the first time it happened it was due to a poor education of one of the schedulers, the 2nd time the person at the lending institution didn't even call me back to explain.

This situation occurs frequently when I bid for assignments on RIMS. Unfortunately, those responsible for assigning jobs often lack the necessary expertise. One local bank has an individual who doesn't speak English and is an illegal immigrant to assign jobs. Great system , eh .

 

[Terrel L. Shields]

Submit a complaint | Consumer Financial Protection Bureau

Find information and tools to submit a consumer complaint to the Consumer Financial Protection Bureau.

www.consumerfinance.gov

Do note they get 25k complaints weekly.

 

[Mejappz]

I recently had two different appraisals canceled and both properties had the same lender, same buyer/seller and Realty company involved. The first time okay, but a second time there is something afoot. There is no AMC the lender orders their own appraisals. I called after the 2nd cancellation and asked to talk to the AIR violation person at the lending company. The first time they said it was due to ignorant or not well educated appraisal scheduler. The 2nd time she didn't comment on at all. Nothing more was done about it, and the lender made loans on both properties. Past the lender or a AMC, who do you report a violation to? I work in Florida and I have already made two separate complaints to Florida Office of Financial Regulation. The first time they acted like it was not in their wheelhouse to make a decision on the complaint so they closed it without doing anything about it. Is there a federal agency you are suppose to let know about this?

Jeff

On the state level you can try Ashley Moody's office.

Home | My Florida Legal

www.myfloridalegal.com

 

[CGinMN]

I have appraised one property for the seller which is also a Realtor. It was a situation where the appraisal came back substantially lower. When I asked him for his CMA, he sent me sales from two counties away when there were ample sales in the subject county, they just did not meet his value he was trying to obtain.

Wow OK, you are just adding more and more details at this point. Next are you going to say you have the emails to prove it? That is basically what you would need to prove a violation.

You should be trying to strengthen the relationship between yourself and the lender, not asking for their "AIR violation person" to threaten them based on a theory you can't substantiate.

 

[apprtech]

On the state level you can try Ashley Moody's office.

Home | My Florida Legal

www.myfloridalegal.com

Who does she work with? Which department?

 

[TerryRohrer]

I have appraised one property for the seller which is also a Realtor. It was a situation where the appraisal came back substantially lower. When I asked him for his CMA, he sent me sales from two counties away when there were ample sales in the subject county, they just did not meet his value he was trying to obtain.

That is where the process started.