Roger Kinnard
Sophomore Member
- Joined
- Jan 29, 2005
- Professional Status
- Certified Residential Appraiser
- State
- Florida
Mike Rogers, the vice chair of FREAB came by and gave a talk to our local association of realtors appraisal committee today.
It was an interesting session. He is very much an advocate of appraisers (anti AVM and AMC) and has a first hand understanding of the situation that we are faced with today. I was impressed by his honesty with us and I'm glad he is on the board.
The majority of our membership is comprised of residential appraisers who primarily do mortgage work. He made it very clear to us that we are targets and that we need to act a little paranoid. He explained the process involved when dealing with complaints and made some good suggestions about how to protect yourself when, not if, it happens to you. He said they are expecting around 1500 complaints over the next year, almost double from the previous year. He advised us all to take some extra time to make sure that our files were as bullet proof as possible and detailed some things that the invesigators are looking for.
Some items of interest he specified
- Be as honest and forthright as possible when dealing with the invesigators. They are trained to catch on to any sort of dissembling and react aggressively when they sense that they are not being told the entire truth.
- Get a lawyer immediately when you get the dreaded letter, preferably one that is skilled in admistrative law. He even noted several that they saw repeatedly that were very good at handling this sort of case.
- Make copies of your M&S pages and keep them in the file. Not an absolute neccesity, but better than trying to reproduce your numbers while an investigator is standing over your shoulder.
- When making a correction on an appraisal, make another file and reference the previous file.
- Summarize your HBU analysis, even if it's obvious. They haven't dinged any one on that yet, but they will in the future.
- Document, document, document everything as if every appraisal that you write is going to be looked at by the investigators. Be as transparent as possible.
- Make a note in the appraisal about every adjustment. Even if it's for bathroom count. Also note non adjustments like a difference in site size of less than 10%.
- When sending a report through a portal that breaks up the report, we are still very much responsible for the end result.
All in all, it was a great learning experience. As someone who has had a complaint filed against them (dismissed at probable cause), I've had some insight into what is involved & the anxiety that you go through, even if you know that you did nothing wrong. The purpose of FREAB is to protect the public through ensuring compliance and knowing how to comply and what they are looking for makes it much easier.
It was an interesting session. He is very much an advocate of appraisers (anti AVM and AMC) and has a first hand understanding of the situation that we are faced with today. I was impressed by his honesty with us and I'm glad he is on the board.
The majority of our membership is comprised of residential appraisers who primarily do mortgage work. He made it very clear to us that we are targets and that we need to act a little paranoid. He explained the process involved when dealing with complaints and made some good suggestions about how to protect yourself when, not if, it happens to you. He said they are expecting around 1500 complaints over the next year, almost double from the previous year. He advised us all to take some extra time to make sure that our files were as bullet proof as possible and detailed some things that the invesigators are looking for.
Some items of interest he specified
- Be as honest and forthright as possible when dealing with the invesigators. They are trained to catch on to any sort of dissembling and react aggressively when they sense that they are not being told the entire truth.
- Get a lawyer immediately when you get the dreaded letter, preferably one that is skilled in admistrative law. He even noted several that they saw repeatedly that were very good at handling this sort of case.
- Make copies of your M&S pages and keep them in the file. Not an absolute neccesity, but better than trying to reproduce your numbers while an investigator is standing over your shoulder.
- When making a correction on an appraisal, make another file and reference the previous file.
- Summarize your HBU analysis, even if it's obvious. They haven't dinged any one on that yet, but they will in the future.
- Document, document, document everything as if every appraisal that you write is going to be looked at by the investigators. Be as transparent as possible.
- Make a note in the appraisal about every adjustment. Even if it's for bathroom count. Also note non adjustments like a difference in site size of less than 10%.
- When sending a report through a portal that breaks up the report, we are still very much responsible for the end result.
All in all, it was a great learning experience. As someone who has had a complaint filed against them (dismissed at probable cause), I've had some insight into what is involved & the anxiety that you go through, even if you know that you did nothing wrong. The purpose of FREAB is to protect the public through ensuring compliance and knowing how to comply and what they are looking for makes it much easier.
