Collateral Underwriter "suggested Comparables"

[timd354]

Denis,

Do you find ANYWHERE, that says if the lender is passing on all 20 comps to the appraiser, or if clients are still mandating that adjustments be within the old guidelines that appraisers can report this to Fannie?
A client never could mandate that the adjustments had to be within 15% net and 25% gross and any appraiser who accepted such an assignment condition in the past or does so new is likely in violation of USPAP. However, clients could in the past and still can require an explanation from the appraiser anytime the adjustments exceed a specified percentage as part of the assignment conditions

Or is it just another one of those things that only has ramifications for appraisers, and portals to report appraiser non-compliance with no way for the appraisers to show what's going on?

The thread that Danny Wiley started has some posts that clients are already notifying appraisers they don't care what's in the letter and that line/net/gross adjustment comments will still be required.
Why wouldn't appraisers comment when net and or gross adjustments are atypically high? Since sales that require higher than typical adjustments are obviously generally not as good of an indicator of value than comparable sales with lower adjustments, appraisers should comment on the necessity of using comparable sales that required large net and or gross adjustments. It is actually pretty sad that some appraisers would have to be asked to include such comments and even more sad that some appraisers are interpreting Fannie's guideline change as justification for not providing appropriate explanations when needed

.

Marian, lenders are free to impose additional requirements over and above the minimum of what is required by Fannie Mae including a requirement for an explanation when the net/gross guidelines exceed 15%/25%.

 

[form1025]

Marian, lenders are free to impose additional requirements over and above the minimum of what is required by Fannie Mae including a requirement for an explanation when the net/gross guidelines exceed 15%/25%.

I would agree to this statement, if of course the assignment conditions / engagement letter specify this criteria, if not and it was asked of me,my rejoinder would cite Fannie's language relevant to the request.

 

[timd354]

the hvcc was created to enforce a current law. a law/rule/reg to enforce a law. one wonders why there is suspicions.

The HVCC was created because the existing federal regulations barring loan officer and mortgage broker selection of appraisers were widely ignored and not enforced...that should not be a terribly difficult concept to grasp.

Its too bad that 5 or 6 years later you are still bitter about losing the ability of your mortgage broker and loan officers buddies to direct the appraisals on the loans they originated over to you.

 

[timd354]

I would agree to this statement, if of course the assignment conditions / engagement letter specify this criteria, if not and it was asked of me,my rejoinder would cite Fannie's language relevant to the request.

That is a reasonable position to take

 

[Meandering]

Marian, lenders are free to impose additional requirements over and above the minimum of what is required by Fannie Mae including a requirement for an explanation when the net/gross guidelines exceed 15%/25%.

Thanks Tim,
I was more wondering about the AMC sending over 20 comps to address/add to the report.

 

[Mr Rex]

There are so many unanswered questions. If I include my search parameters and all of the "comparables" in the search criteria, will CU question my opinion and require further summary of why I stuck to Cert 7? If I pre-answer why I used the comparables I used and didn't use, does CU still send it back to the lender (and appraiser) for further explanation?

 

[Meandering]

Yes

 

[djd09]

The HVCC was created because the existing federal regulations barring loan officer and mortgage broker selection of appraisers were widely ignored and not enforced...that should not be a terribly difficult concept to grasp.

Its too bad that 5 or 6 years later you are still bitter about losing the ability of your mortgage broker and loan officers buddies to direct the appraisals on the loans they originated over to you.

none of my "officer buddies" ever dictated what value was inserted into the appraisal and if someone did they were not my client anymore. are you implying that i have disregarded my independence during that time?

 

[timd354]

none of my "officer buddies" ever dictated what value was inserted into the appraisal and if someone did they were not my client anymore. are you implying that i have disregarded my independence during that time?

I am suggesting that you had no independence to disregard since those who selected you as the appraiser (mortgage brokers and loan officers) had a vested interest in selecting an appraiser who would make their deals work so that they would get paid there commissions as opposed to selecting a qualified appraiser. This does not mean that you personally neccesarily did anything wrong, but the fact that loan officers and mortgage brokers were allowed to select the appraiser was an obvious inherent conflict of interested that corrupted the system and compromised appraiser independence. Additionally, since 1992, appraiser selection by loan officers and mortgage brokers in a regulated 1-4 unit mortgage transaction was illegal. If you can't see the obvious and inherent conflict of interest if loan officer/mortgage broker selection of the appraiser, then you are beyond help. Not that it matters, because despite your longing for the good old days when your loan production buddies could steer the appraisals on their loans over to you, those days are never coming back as mortgage brokers and loan officers will never be allowed to pick the appraiser again.

 

[timd354]

What hasn't been in the past 5+ years?

Name one.

Sorry, Marian, but I am not playing that game. I could name same some changes in the past 5 years that I believe were beneficial and you would undoubtedly argue that those changes were horrible and somehow screwed over appraisers, so what's the point?