Defund TAF

[DWiley]

I think its BS to blame the ASC or FFIEC or TAF or the GSEs for what the lenders are doing. And the only reason the lenders did it was because they could. Because there is so much competition that it didn't cost them a dollar extra to require a CR to do the appraisal instead of an SL licensee or a Trainee inspecting without a CR being present.

I was at a meeting once where a group of AMCs was meeting with a group of lenders to encourage allowance of trainees, and that was exactly the response from the chief appraiser at a very large lender - "Why the he** would I want the word "trainee" on the report when I can get a CR at the same price?" He viewed as a built in reason for a borrower to challenge an appraised value that the borrower did not like.

Despite what some fervently believe, when I was in AMCland, it was all driven by the lenders. Some did not allow trainees, period. Some would say that they allowed trainees, but then adopt policies that made it operationally impossible to do so.

 

[George Hatch]

I don't think so. I have never come across an engagement letter from a lender that does not use an AMC say that trainees are not allowed. As a matter of fact, most of the engagement letters or service agreements specifically state that trainees are allowed. That includes Guaranteed Rate, a nonbank that depend on investors.

The hangup isn't allowing trainees. The hangup is allowing did not inspect by the Supervisor. The supervisors can't make money off trainees legitimately if they have to personally inspect.

 

[Joe Flacco]

I went through some old Clear Capital requests in my email. It looks like around 2013-2014 the no trainee requirement for Chase and Wells Fargo was initially under "Customer Requirements". But then it looks like around 2015 it was moved out of the "Customer Requirements" and into the "Standard Requirements" which seems to be Clear Capital requirements.

 

[Joe Flacco]

The hangup isn't allowing trainees. The hangup is allowing did not inspect by the Supervisor.

No ****.

 

[George Hatch]

But you do catch my point. The trainee-dependent sweatshop is only financially viable if the lenders will accept a "did not inspect" Supervisor's signature. Which to date they mostly haven't been accepting. However, they could all reverse course and do so if they ever actually ran into a shortage of appraisers. That's what makes all the fretting about appraisers dying off such a ridiculous argument. The lenders could solve their own problem any time they wanted to. They don't need any external "programs".

 

[Joe Flacco]

Clear Capital and STARS are the only AMCs I have experience with. I don't recall if STARS had a no trainee requirement. Clear Capital does. All direct lenders except for one that I have experience with allow trainees.

 

[Joe Flacco]

But you do catch my point. The trainee-dependent sweatshop is only financially viable if the lenders will accept a "did not inspect" Supervisor's signature. Which to date they mostly haven't been accepting. However, they could all reverse course and do so if they ever actually ran into a shortage of appraisers. That's what makes all the fretting about appraisers dying off such a ridiculous argument. The lenders could solve their own problem any time they wanted to. They don't need any external "programs".

I am saying most banks that I know allow trainees to inspect without the supervisor not inspecting.

My exposure to banks is limited to like maybe 10 banks. But that is what I have seen with regards to trainees.

 

[George Hatch]

I only work with direct lenders (albeit portfolio lenders) and none of the ones I work with have ever allowed "did not inspect".

My perception of the AMCs s that they'll do anything to get ahead of their competition if allowed to do so. They have no motive to be uncooperative with a lender who is willing to accept "did not inspect".

 

[Joe Flacco]

That is pretty unusual. My experience is that the community banks tend to have no additional requirements at all.

 

[djd09]

The hangup isn't allowing trainees. The hangup is allowing did not inspect by the Supervisor. The supervisors can't make money off trainees legitimately if they have to personally inspect.

AI Overview

Yes, according to Fannie Mae guidelines, the appraiser who signs the appraisal report is the one who is responsible for inspecting the property. This includes both the interior and exterior inspection, as well as the exterior inspection of comparable sales from at least the street, according to Fannie Mae. The appraiser's signature on the report signifies that they personally performed these inspections and developed the opinion of market value.

Here's a more detailed breakdown:

• https://www.google.com/search?rlz=1...oNiofEpCvcEOSgzZu_MFbFy-KYEH0ZWRXBeY64&csui=3
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