- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
You may have forgotten your Appraisal 101 course but appraising has been around for hundreds of years.
The Appraiser's Petition was a complaint about external pressure to lie on behalf of the loan originators in order to enable them to cheat their own trading partners. The angle we argued was that the persistent and significant overvaluations which ensued represented a threat to the safe/sound lending. The only reason anyone even remembers that petition is because most of those allegations were subsequently proven.
There are no parallels between "appraisers are being coerced to conspire to cheat the lenders" vs "appraiser splits are too low" "AMCs are taking too much of the fee" or "only appraisers should be collecting subject property attribute data"
We can allege that waivers and hybrids are resulting in significant overvaluations, serious enough to undermine safe/sound lending. But this isn't a racism argument so merely making the allegation isn't considered to be prima facie proof of the allegation as is the case with the appraisers-r-racist allegation - wherein the burden of proof rests with the accused. For our "danger to safe/sound" allegation the burden of proof defaults back to accuser, not the accused. We gots to back the "threat to the public" allegation with some proof.
That's not to suggest that "significant overvaluations" aren't actually occurring. Maybe they are. But we don't have any indications of that yet - not on any significant scale.
IMO what the GSEs should actually care about is whatever truths we are conveying. Not how we feel about those truths.They should care what appraisers think since bulk of GSE lending orders still use appraisals - and a hybrid is an appraisal. Nobody cared much what appraisers thought wrt our petition and posting about the dangers of the pre-bubble run-up in prices - and we were right. Could have saved the nation billions in lost equity and foreclosures etc but whose counting....
The Appraiser's Petition was a complaint about external pressure to lie on behalf of the loan originators in order to enable them to cheat their own trading partners. The angle we argued was that the persistent and significant overvaluations which ensued represented a threat to the safe/sound lending. The only reason anyone even remembers that petition is because most of those allegations were subsequently proven.
There are no parallels between "appraisers are being coerced to conspire to cheat the lenders" vs "appraiser splits are too low" "AMCs are taking too much of the fee" or "only appraisers should be collecting subject property attribute data"
We can allege that waivers and hybrids are resulting in significant overvaluations, serious enough to undermine safe/sound lending. But this isn't a racism argument so merely making the allegation isn't considered to be prima facie proof of the allegation as is the case with the appraisers-r-racist allegation - wherein the burden of proof rests with the accused. For our "danger to safe/sound" allegation the burden of proof defaults back to accuser, not the accused. We gots to back the "threat to the public" allegation with some proof.
That's not to suggest that "significant overvaluations" aren't actually occurring. Maybe they are. But we don't have any indications of that yet - not on any significant scale.