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Collateral Underwriter "suggested Comparables"

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Having these guidelines were one of the contributing factors in creating the CU, many appraisers felt compelled to stay below these thresholds by using incorrect data/adjustments. As noted competent appraisers would explain their derivatives whether or not these guidelines are/were in place. When certain guidelines such as these are disseminated many in the industry take this as law and that it is mandatory ,hence improper interpretation which leads to improper comp selection which leads to improper adjustments which lead to the CU.

I agree,
and I disagree with Scott. Sorry Kebbs.

Within the report, especially the market conditions section and the reconciliation, should be the information that details why there are few to no similar comps in the subject's market area. There is a tiny check box on the bottom of page one that says the subject does or does not conform to the neighborhood. All of that is a pathway to why adjustments can be large. Reports are meant to be read. The computer should see that the check box for conformity is checked or not. No additional discussion beyond conformity, market and reconciliation should be needed to say, the gross adjustment of comp 3 is larger than 25% because there were no other similar comps in the market area and this was the next best sale that would have been considered by a typical buyer of the subject property and was therefore used in the report. It's redundant BS to meet an ill contrived box in which to fit as much real estate as possible, while herding the cats into similar decisions concerning what is and is not comparable.

I would say, from their own BS, that if your adjustments exceed the old guidelines, then it was a complex assignment and due an additional charge.

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Interesting that CU issues warnings when some adjustments diverge from peer standards but openly criticizes those peers when it pertains to GLA. You know good and well there's similar peer adjustment problems all over the grid. I'm not criticizing the CU for it, after all you have to start somewhere, but pointing out one reason pretty much everybody is going to be getting hit with CU messages early on. I suspect the peer database is somewhat of a mess and it will take time to smooth out.


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Agreed. And now, that so many appraisers are announcing they have never used GLA adjustments less than $6000/sf anyway, the difference in the average $/sf peer adjustment for the next quarter Fannie decides to analyze will be interesting to say the least. The GLA adjustments may be so high, there will never be a reason to adjust for another property characteristic again. Who needs a list.
:LOL::LOL:
 
Well, I can't tell you how many times I have blown through the guidelines. But I have performed appraisals on a bunch of lower/middle income housing. So the 15/25 guidelines are not a good thing imo. I'm glad they are gone, not that they really bothered me much anyway. Like a mosquito maybe. And I can tell you what I do to a mosquito.
 
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Removing the 15/25 guideline appears to be a result of UAD policing itself, or it's maker.
 
Removing the 15/25 guideline appears to be a result of UAD policing itself, or it's maker.
Huh? The 15/25 guidelines were removed because the UAD provided the data that allowed Fannie to do an analysis that showed that this guideline was having the unintended effect of causing some appraisers to manipulate their adjustments to fit within the guideline. Before the UAD, such data was not available.
 
Huh? The 15/25 guidelines were removed because the UAD provided the data that allowed Fannie to do an analysis that showed that this guideline was having the unintended effect of causing some appraisers to manipulate their adjustments to fit within the guideline. Before the UAD, such data was not available.

I know. That's what I mean. UAD has indicated it was a bad guideline. I agree with UAD in that respect, because I know sometimes the best comparables do not follow the 15/25 guideline. Some people obviously took it in too much of a concrete sense.
 
Sorry, Timd, i also should have added the 15/25 might have not only kept some from choosing the best comparables, but also kept some from performing the proper analysis (adjustments), which obviously UAD has indicated, which resulted in the removal of the guideline. Good move all the way around, imo.
 
Of course those indications from CU/UAD relative to the 15/25 guideline make me question both the amount of time being input in the valuation process in some cases, as well as the skill level of the labor being utilized in some cases. So, the impact of those analysis from UAD are prolly not over. We can confidently assume that, because if the indications were strong enough to remove the guideline, they will be strong enough to discipline and/or correct some more things.
 
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Mister Peabody's compressed timeline would look something like: Crooked LOs and appraisers get caught, > HVCC; HVCC didn't work, > DF; DF has muddied the waters > CU.

All of us get that there was collusion between lenders (processors, closers, LO's, branch and regional production managers etc.) and appraisers to move loans through a system that coveted the implied federal guarantees that removed (most of) default/foreclosure risk to the Feds. We're also aware that appraisers who balked at this pressure soon got bypassed. But I think that if anyone looking at the residential mortgage loan production system and the investment community hungry for some level of interest return above the T-bill rates - if anyone thinks that the drives have changed is looking for the Jim Jones Kool-Aid recipe. Yep, we've got a pretty effective firewall between commissioned loan hacks and appraisers. But what we still have is a system that - at some point - will not tolerate appraisers who do not, at least most of the time, produce the results that the lenders require. (Yep, there's still cleaning up to do on appraisals/appraisers; yep appraisers have been allowed to submit a lot of white bread (non-substantive appraisals) for GSE work for decades; yep appraisers need to do a better job of telling what they've done.

But, lenders still control the approval of appraisers on their approved rosters, and while the assignment of particular appraisals to particular appraisers is out of the LOs' control, appraisers who refuse to produce the desired result will lose assignments and will (probably) be removed. Five years ago, it was the number and the lack of appraisal-related requirements that were the trigger. Perhaps tomorrow it will be really thorough appraisal reports with cogent explanation of every pertinent part of the process that conform to mandated descriptors.

At some point up the food chain in the lenders' corporate structures there is a point at which quality control and production/profit mandates meet. There is an inherent institutional bias to maximize profit and minimize risk, and while there may be a weighting of incentive compensation for quality issues, production and profit incentives are primary. This production/profit mandate is ubiquitous, and at the top of the pyramids is (still) the federal government as the ultimate guarantor of the incentive comp generated throughout the MF system (that would be the mortgage finance system).

And, yep, we're back to high ratio loans, eased federal loan standards and all the rest. (I'm not aware that we're back to no-doc loans), but we continue to hear that credit and income standards are inherently discriminatory. There's no conspiracy - but the legislators and regulators don't understand that those who are profiting in the current environment are still way ahead of them.
 
Every skilled and honest appraiser should hope that CU succeeds in weeding out the fraudsters and the unskilled members of the appraisal profession.

Every skilled and honest appraiser should hope that their work is held to USPAP standards by a licensed and experienced professional, rather than wasting time answering to a sloppy computer program that was built on flawed valuation theories such as rote formulas for GLA adjustments and choosing comps based on census tract. They have had MILLIONS of opportunities to catch the fraudsters already, the fact is they don't care, basic QC and enforcement have been both at levels close to ZERO for decades now. Everyone gets their fees for closing the deal, the numbers are looking good this quarter, if the appraisal becomes a problem down the road then they can just file an E+O claim, done deal.
 
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