Comp Checks and FHA, where to send

[Fred]

You must be very popular.

Watch out there, ZZ. Even though your point is valid, instead of saying comp-check followed by appraisal, say appraisal followed by an update. By avoiding the hot button word, you won't get the natives restless.

The problem with the free so-called "comp check" is not that the individual appraiser is doing something wrong, per se. It's that LO's and MB"s perpetually shopping for the highest available opinion on every property creates nationwide undiscounted collateral risk.

You can send out 100 average-Joe compent appraisers, lend 90% of the total value, and have a pretty sound bet. Take those same properties, with appraisal contracts shopped to the person willing to come in wth the highest value, lend 90% of that, and I almost guarantee you'd be upside down. Glad to see FHA seems to have figured that out (he said with fingers crossed).

 

[Kevin Mc]

You can send out 100 average-Joe compent appraisers, lend 90% of the total value, and have a pretty sound bet. Take those same properties, with appraisal contracts shopped to the person willing to come in wth the highest value, lend 90% of that, and I almost guarantee you'd be upside down. Glad to see FHA seems to have figured that out (he said with fingers crossed).

Outstanding. That ZZ is why comps checks are (and have been) a problem.

 

[LadybugLover]

Thanks for updating the email address. I too had sent her an email and it bounced back. Just resent it and hopefully will hear from her regarding a Reverse Mortgage issue I've had pending since December of 2007.

Mary

 

[xmusienb]

Here's another option:

Mortgagee Letter 2008-09 states that FHA WILL deal with inappropriate Lender (and appraiser) actions when they are reported.

The method to report inappropriate FHA assignment requests, value pressures, etc. is as follows:

Email them to:

HUD@custhelp.com

FHA will investigate the matter and assign it to a Regional HOC Center for disposition.

A few requirements

1) Subject Line should state "Lender Complaint."

2) Attach a copy of the offending appraisal request is that is the problem.

3) Given the address, Case #, and zip code of the property if it is not already in #2 above.

4) Attach any and all written documents to the email.

 

[Joshua Fookes]

sorry

I tried to edit my original post to correct the email address, but can't log into that post to do such. If a moderator could help???

Josh

 

[Gajope]

I thought we were supposed to be "FHA experts"

 

[Joshua Fookes]

I need to find the specific instruction about this to send to a mortgage broker. Anyone know the reference?

Mortgagee Letter 99-32 FAQ's (page 10 of 11) This is a Lender Q&A section.

1. Section 1-2 Section C. Communication with appraisers: The Handbook says that HUD advises the appraiser to only talk to the DE Underwriter about an appraisal before it is completed. Also, no other person should talk to the appraiser. This seems to be a bit impractical. A lot of times the appraiser has small problems that wouldn't even have anything to do with the DE Underwriter. Does this mean that after a sponsored mortgage broker i.e. lender, orders an appraisal, we are not supposed to talk to the appraiser until it is received? A lot of times, an appraiser will call just to let us know a property isn't going to work, can't find comparable, etc. Are we not to have that kind of relationship with the appraisers anymore?

No one but the underwriter is to discuss the VALUE with the appraiser until the appraisal is completed. The appraiser can discuss the physical characteristics or schedule an appointment with the seller or their representative. Consistent with FIRREA, the appraiser may not discuss the value with anyone else but the client. The client is the lender.

Comp checks fly in the face of this policy.

Note the date of the Mortgagee letter, this isn't new stuff here folks.

Josh

 

[Mutyger]

Does anyone have a contact on this for the Denver Home Ownership Office as well as the Atlanta Home Ownership Office?

 

[xmusienb]

Does anyone have a contact on this for the Denver Home Ownership Office as well as the Atlanta Home Ownership Office?

HUD@custhelp.com

Mortgagee Letter 2008-09 states that FHA WILL deal with inappropriate Lender (and appraiser) actions when they are reported.

The method to report inappropriate FHA assignment requests, value pressures, etc. is as follows:

Email them to:

HUD@custhelp.com

FHA will investigate the matter and assign it to a Regional HOC Center for disposition.

A few requirements

1) Subject Line should state "Lender Complaint."

2) Attach a copy of the offending appraisal request is that is the problem.

3) Given the address, Case #, and zip code of the property if it is not already in #2 above.

4) Attach any and all written documents to the email.