Now....
The majority of MY clients have nothing to do with Corelogic. I upload my reports to their own portal and they send it to Fannie Mae.
So is alamode going to share my reports to Corelogic without my clients permission? That is the question.
That is one question: I doubt (but I could be wrong) if there is a law prohibiting Corelogic from mining data from sources they are not permitted to mine, then they will mine them anyway. Why should they? The have tons of data already and data mining is one of the things they do in a compliant manner.
But another question is this: What's to stop the assigns or investors that your other banking clients may use, from delivering the reports through a system that will data mine the appraisal and where those parties have agreed to that?
Cert#21 defines what can be done with the report by the client without obtaining permission from the appraiser. But Cert#21 doesn't restrict what can happen to the report once it is distributed to those identified on the distribution list.
Personal financial information is covered under different regulations. But it is hard to argue that physical/factual information (size) or even a qualitative rating (C3) would fall under confidential financial information (as the laws are written now).
I'm not in favor of data mining. I'm not necessarily opposed to it either. I am in favor of following the rules and regulations. Cert#21 outlines the rules we follow and what we acknowledge the client can do with our report. But that's where it stops; it doesn't prohibit additional distribution after that whether we like it or not.
The only good news I see for those who are opposed to data mining is that with the recent headlines about data mining of personal information and on-line viewing habits, data mining in general is front and center for many decision-makers' (and the public's) radar. So raising the alarm flags to get things changed now might be the best opportunity to do so.
However, under current rules/regulations, once the appraisal leaves our hands and goes to the client, there are no real barriers to stop the appraisals from being data mined: the client can do it, and the secondary market participants or investors can do it, and certainly GSE or government agencies can do it. The only handicap to doing it before was the non-uniformity of how the data was encoded and how components were identified. For residential mortgage work, both the data format and the reporting format has been standardized, so that handicap is gone.
IMO, if one wants to stop appraisal data mining from 3rd party data collection agencies, one is going to have to get some laws introduced that identify property data as financial or consumer data and require that the consumer affirmatively opt-in to the share.
Short of that, I don't see it happening.