Fannie Mae and "Multiple Parcels"

[George Hatch]

They never said there was no conflict with Fannie. How could they? Fannie is no more of an appraisal entity that First National Sasquatch Bank.

I remember when I first came to this forum there were actually people who thought there was a choice to be made between Fannie-World or VA-World vs USPAP. It took me and several others a couple years to either convert them or run them off.

 

[djd09]

Irving Fisher

Big Irv. Yeah, right, petty economist with pants to match.

 

[J Grant]

They never said there was no conflict with Fannie. How could they? Fannie is no more of an appraisal entity that First National Sasquatch Bank.
I remember when I first came to this forum there were actually people who thought there was a choice to be made between Fannie-World or VA-World vs USPAP. It took me and several others a couple years to either convert them or run them off.

I agree, appraisers follow USPAP - however, Fannie is becoming an appraisal entity- a shift from fannie being a recipient of appraisers to being an originator of them - in part at least, via their ordering of a data collection instead of appraiser inspect, and their own in house valuation determining what level (if any) appraisal to be done from there. .
Fannie said, okay, appraisers have to follow USPAP, but WE do not! So we can insert OUR portion into an appraisal to get it faster -and or control the process.

 

[Carnivore]

Since the beginning of when appraisers were regulated by State and Federal laws all other parties/data sources have not really been regulated as it relates to appraisers/appraisals. Yes, there are rules and regulations pertaining to Controlling Municipalities. Lenders were brought into this under Federal Regulations and Even State Regulations for certain types of Lenders. Hard Money Lenders have much greater freedom. Its because they are not using public monies. That is the fundamental difference.

So to say Lenders of any type do not have to comply with USPAP is incorrect. Some do, some don't. Even Mortgage loan type lenders don't all have to comply with federal and state regulations. Everyone including business in general fall under criminal Statutes.

 

[J Grant]

Since the beginning of when appraisers were regulated by State and Federal laws all other parties/data sources have not really been regulated as it relates to appraisers/appraisals. Yes, there are rules and regulations pertaining to Controlling Municipalities. Lenders were brought into this under Federal Regulations and Even State Regulations for certain types of Lenders. Hard Money Lenders have much greater freedom. Its because they are not using public monies. That is the fundamental difference.

So to say Lenders of any type do not have to comply with USPAP is incorrect. Some do, some don't. Even Mortgage loan type lenders don't all have to comply with federal and state regulations. Everyone including business in general fall under criminal Statutes.

There is a difference between USPAP, which only applies to appraisers, and those federal or state regulations which can apply to lenders/banks/fannie.

 

[Carnivore]

This is the forever thread. Ya''ll do know that there is another FAQ that can create the same problem! FAQ #197 current USPAP

Its true that FQ's are not part of USPAP.

That just means that there are lots of considerations that an appraiser must take into account dependent of the Client and Intended Use. These really effect Residential Appraisers because we often do not have nor are allowed direct contact with the Client. Majority of the Mtg Loan assignments go through the Intermediary AKA AMC Phone Monkey Dot Com.

So I have a point to make in the form of a Question: How are we to know what Federally Banking Regulations our client must follow or comply with?

The USPAP FAQ answer seems to be over-simplified. We ask our client Questions. This raises another Question. How do we know what questions to ask?

USPAP FAQ says: "....the appraiser must be aware of the current guidelines(or regulations,(if applicable) Really! If they don't tell us, then do we just assume there may not be any pertinent regulations/rules. That's not a good answer. If we ask, and they tell us none that concern us or the assignment. Is that a get out of Jail Card?

We know that in this specific assignment that there are three Opined Value. 1. Site with improvement 2. Site Value without the Improvement. That's in majority of FNMA/Lender SFR assignments. We short cut reporting of the Site Value of the improved subject. in other words we don't demonstrate the analysis in the URAR. Its in our work file, but its just often reported in the Cost Approach section at the top. 3. Value of both sites combined.

But it for the FAQ's How do we know what OTHER regulations and Laws the Client must comply with?

 

[J Grant]

But it for the FAQ's How do we know what OTHER regulations and Laws the Client must comply with?

We probably don't know, unless we devote enormous time to finding out. Though many appraisers have a working idea of some lender regs.

But never forget that we are appraisers and they are clients. Their role is to hire and pay us, then we part ways . Appraisers have to comply with USPAP, it is outside our bailiwick what regulations / laws a client or lender must comply with , or if if they are complying.

If you want to pore over Frank Dodd and FHA handbook and state legislation to search regulations applicable to lenders/clients, go for it. But that will still not inform you know whether or not a client is complying .. Not sure why the concern, but it is common sense to ditch a client who tries to influence an appraiser to change a value, or fudge a property condition in their favor..

 

[George Hatch]

This is the forever thread. Ya''ll do know that there is another FAQ that can create the same problem! FAQ #197 current USPAP

Its true that FQ's are not part of USPAP.

That just means that there are lots of considerations that an appraiser must take into account dependent of the Client and Intended Use. These really effect Residential Appraisers because we often do not have nor are allowed direct contact with the Client. Majority of the Mtg Loan assignments go through the Intermediary AKA AMC Phone Monkey Dot Com.

So I have a point to make in the form of a Question: How are we to know what Federally Banking Regulations our client must follow or comply with?

The USPAP FAQ answer seems to be over-simplified. We ask our client Questions. This raises another Question. How do we know what questions to ask?

USPAP FAQ says: "....the appraiser must be aware of the current guidelines(or regulations,(if applicable) Really! If they don't tell us, then do we just assume there may not be any pertinent regulations/rules. That's not a good answer. If we ask, and they tell us none that concern us or the assignment. Is that a get out of Jail Card?

We know that in this specific assignment that there are three Opined Value. 1. Site with improvement 2. Site Value without the Improvement. That's in majority of FNMA/Lender SFR assignments. We short cut reporting of the Site Value of the improved subject. in other words we don't demonstrate the analysis in the URAR. Its in our work file, but its just often reported in the Cost Approach section at the top. 3. Value of both sites combined.

But it for the FAQ's How do we know what OTHER regulations and Laws the Client must comply with?

We can know what they ask for. We can know what their written appraisal policies are. We can respond to their stips and questions and learn their quirks that way.

We can always ask at the outset of our relationships.

As I have said many times before on this forum, IMO the single biggest thing a lender can do for themselves to improve the quality of the appraisals they get in is to develop and promulgate the comprehensive written appraisal policy, post it on their website, and maintain it on the ongoing basis. Then include the link to that policy in every engagement letter or "order form" they use. Then nobody has any excuse for "not knowing" what goes into that assignment.

Then chain their reviewers to it. The reviewers don't get the discretion to move one inch off that written appraisal policy. It applies just as much to what they're doing as it does to the appraisers.

IMO appraisers need to get away from the concept of the one-size-fits-all widget. The reliance on that unsupported assumption is unnecessary and unprofessional.

 

[Carnivore]

We can know what they ask for. We can know what their written appraisal policies are. We can respond to their stips and questions and learn their quirks that way.

We can always ask at the outset of our relationships.

As I have said many times before on this forum, IMO the single biggest thing a lender can do for themselves to improve the quality of the appraisals they get in is to develop and promulgate the comprehensive written appraisal policy, post it on their website, and maintain it on the ongoing basis. Then include the link to that policy in every engagement letter or "order form" they use. Then nobody has any excuse for "not knowing" what goes into that assignment.

Then chain their reviewers to it. The reviewers don't get the discretion to move one inch off that written appraisal policy. It applies just as much to what they're doing as it does to the appraisers.

IMO appraisers need to get away from the concept of the one-size-fits-all widget. The reliance on that unsupported assumption is unnecessary and unprofessional.

Agree! I would add to reviewers as including the AMC & their Checker Dudes. I think this is where a lot if not most of the problems may be coming from.

 

[offtherecord]

I don't want you to take this the wrong way, but I think one of the reasons for some of the pushback you're getting are the constant references to who agrees with you - aka the appeal to authority. I think your explanations of the reasoning - which also motivates other people to agree with you - is sufficient to the task.

Appraisers don't tend to have a whole lot of respect for authority figures. IMO

And kind of with good reason.