WAIVERS are low-tech. What is advanced tech about a borrower or lender writing in their own estimate of value for a property?
I agree we can and should embrace technology. I don't believe AI can replace an appraiser; an appraiser can use it well or poorly.
You're missing the point of the appraisal modernization program.
They don't want to replace appraisers. They are substituting independent value opinions with their own controlled in house proprietary avm's.
We have investigated ourselves and determined everything is o.k..'
Waivers and their own 'rules.' The AVM final rule. All lenders need to do is fill out a two page form every other year to self certify their internal valuation programs which are not subjected to any external oversight or auditing, are not required to be implemented or overseen by anyone with an individual appraisers license, the programs algorithms and internal decision making structures proprietary, are just as good if not better than using actual full service independent appraisers. A two page bi annual valuation program reliability self certification; Just as good as the independent appraisal program. The entire hybrid program is based on similarly watered down rules, that all revolve around their initial avm calculus associated LTV ratios in the first place.
The lesson of Zillow; How does one sell their avm utility ahead of the competition? Higher numbers! Unlike Zillow, the GSE's gamble and are backstopped by the taxpayer. Which is why a structure that lacks balanced accountability and external oversight is unacceptable.
The root cause of the problems here revolve around the disparities regarding multiple different standards applied which leads toward loan origination or subsequent liquidation. Think of this as a departure from standard mathematical order of operations guidelines. Depending on the situation and need, order the mathematical sequence however you would like, a singular standard rule no longer applies. Depending on how one structures the 'valuation request', there certainly can and will be variable outcomes.
Dear state of Maryland....
https://appraisersblogs.com/fannie-mae-2-state-of-maryland-drop-dead/
The various individual changes could have been accomplished without a total program radical restructuring. Additional sought after data could have been tagged into new forms which accompanied the tried and true old forms. There is definitely something to be said about the concept that nobody outside of the GSE world will be using a similar form. Again, a variable standard. The modern equivalent of clipping the coin, thumb on the scale, hollowed out weights. Curiously the entire world still relies on standard weights and measures. Except for the GSE's now a days, they're a special exception because they're dealing with real property value which is apparently simply too complicated to have one standardized approach.
Imagine being a consumer against invasive technology such as for instance what's popular now, the flock systems resistance. Only to experience this first hand in your own home from your mortgage lender, when trying to get through a simple refinance. The objections may begin with the vendors and small businesses displaced but they most certainly will not end there. The entire range of objections, process, management, privacy, financial security.
The people pushing this seem to have a really difficult time reading the room. Probably because they're not the ones tasked with doing the actual work, nor will they deal with the consequences of the data brokering. The real truth of data brokering is that the long term income streams associated with this dwarf what used to be a straight forward traditional process of churning products off the line for one time profit tallying. The tokenization of real estate.
Make of the objections what you will. Like the tens of thousands whom came and went before, many are taking a hard turn for the exits.
It may be somewhat difficult to bark never ending mandates to an empty room.
That's where the automatic utilities come in, as designed, as planned.