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Hybrid

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can they be done in a USPAP-compliant manner?
As a question for the individual, yes. But as a question for the industry as a whole, such products invite the less ethical to "make it work". In other words, they simply fill out the form with little or no verification, research and basically PFA... going retro to the 1980s? So while good appraisers are likely to find these low fee offers unacceptable - (why take less than the non-appraiser evaluators charge for the same thing?) - someone somewhere may simply gear up to crunch these puppies out and ditto for those doing the inspection part.... Seems to me the banking industry is inviting a fraud be perpetrated upon themselves...not that they care, it is meant as a compliance document not a serious valuation.
 
As a question for the individual, yes. But as a question for the industry as a whole, such products invite the less ethical to "make it work". In other words, they simply fill out the form with little or no verification, research and basically PFA... going retro to the 1980s? So while good appraisers are likely to find these low fee offers unacceptable - (why take less than the non-appraiser evaluators charge for the same thing?) - someone somewhere may simply gear up to crunch these puppies out and ditto for those doing the inspection part.... Seems to me the banking industry is inviting a fraud be perpetrated upon themselves...not that they care, it is meant as a compliance document not a serious valuation.

OK. That's a reasonable concern and a reason to be against the policy of using these hybrids.
Just to be clear, what I am reading you to say is this:
There are going to be some crooked or very incompetent appraisers who will take this work, and lenders will knowingly use this as a means to get valuations done that hit an objective that they could not get done using the traditional sources.​
I'm not posing this as a trick question. The above is what I'm reading you to say and I'm asking if my understanding is correct. And, I presume the above doesn't mean all appraisers who do this work are crooks/incompetents, but that the process itself lends to crookedness and incompetence by some appraisers (and a willingness of lenders to go along with that).
 
There are going to be some crooked or very incompetent appraisers who will take this work, and lenders will knowingly use this as a means to get valuations done that hit an objective that they could not get done using the traditional sources.I'm not posing this as a trick question. The above is what I'm reading you to say and I'm asking if my understanding is correct.
The desperate (be it incompetent or crooked) rarely see themselves as such, but yes, it would be likely to be a person willing to "push the envelope" (at least in their mind) or are Skippy reincarnate.
The subject of whether the lender knows or not whether the product is "good" or "bad" is a more nuanced assessment. They generally don't care. It's cheap and it satisfies the bank examiners. That is all they care about. I doubt that many lenders rely upon ANY appraisal in their lending decisions. Especially after they realized in a downturn like 2008, that the past appraisal meant nothing. The value was not there even with the best appraisers. After all, when prices fall by 30% plus, no one's appraisal was going to support this new value during the origination appraisal of the past years. So it did not prevent the collapse. it did not predict the collapse and especially could not foretell the actual price the bank would get out of their REOs. Whether someone gutted it out and paid off the loan regardless they were underwater was a testament to their integrity, the depth of their pockets, the stability of their job, and their credit history.
In a housing downturn, the riskiest loans were made to people whose livelihood originated with the housing industry itself. So carpenters, developers, cabinet installers, even brokers and agents, were the ones whose incomes fell dramatically. The local government employee, school teacher, etc. could survive the downturn much better than most. And did.
I suppose that we need to recognize that the bank appraiser is only telling the lender that they are not upside down in the loans they make before they start. And that may predict whether or not someone has enough skin in the game to be a reliable borrower. it is easy to walk away when you have no skin in the game. So the value of our appraisals may only be good on that very day we say it is and not much further out in time. Thus the banker is far more likely to rely upon ones credit and work history rather than the appraisal.
 
The subject of whether the lender knows or not whether the product is "good" or "bad" is a more nuanced assessment. They generally don't care. It's cheap and it satisfies the bank examiners. That is all they care about.
I agree with this however...
I doubt that many lenders rely upon ANY appraisal in their lending decisions.
They do for the banks I work with. Rejected two in the last 30 days. Usually, through the review process, the appraisal can raised to a level of acceptability. Not always, though.

Especially after they realized in a downturn like 2008, that the past appraisal meant nothing. The value was not there even with the best appraisers. After all, when prices fall by 30% plus, no one's appraisal was going to support this new value during the origination appraisal of the past years. So it did not prevent the collapse. it did not predict the collapse and especially could not foretell the actual price the bank would get out of their REOs. Whether someone gutted it out and paid off the loan regardless they were underwater was a testament to their integrity, the depth of their pockets, the stability of their job, and their credit history.
In a housing downturn, the riskiest loans were made to people whose livelihood originated with the housing industry itself. So carpenters, developers, cabinet installers, even brokers and agents, were the ones whose incomes fell dramatically. The local government employee, school teacher, etc. could survive the downturn much better than most. And did.
I suppose that we need to recognize that the bank appraiser is only telling the lender that they are not upside down in the loans they make before they start. And that may predict whether or not someone has enough skin in the game to be a reliable borrower. it is easy to walk away when you have no skin in the game. So the value of our appraisals may only be good on that very day we say it is and not much further out in time. Thus the banker is far more likely to rely upon ones credit and work history rather than the appraisal.
(my bold)

This is it in a nutshell.
Although commercial reports may go a little deeper in terms of supply/demand (which implies some future demand forecasts along with feasibility), residential appraisals... especially GSE-type, rarely go beyond historical (inferred on a very basic level). And, for the majority of the assignments, that's good enough and meets both the client's expectations and work done by a peer.
But the bottom line is the appraisal is only good to mark-to-market the value of the property on that date. It may provide some indication of past trends (rising, stable, declining markets) and it may go an extra mile by discussion pipeline and absorption. But for a routine residential transaction: What's the value so I can calculate the LTV and determine the loan amount. I'm not counting on getting paid back by the collateral, I'm counting on getting paid back by the borrower's ability to service the debt; that is best modeled by credit score and employment history.

That's why, not knowing what the parameters are going to be for these hybrids if they roll out (and I think they will) as a substitute for a traditional appraisal, the question is, how collateral-value sensitive they will be?
Let's assume that a percentage of appraisers doing these (by intent or incompetence) over-value a property on a routine basis by 10%.
If the credit score and employment history is solid, and the LTV for this type of loan is maxed out at 65%, how critical is that 10% over-valuation (mind you, I'm not excusing it or justifying it, I'm just asking the question):
$300k value vs. $330k.
$195k loan vs. $214,500 loan (@65% LTV).
P&I monthly payment difference at 5%, 30-years, fixed?
$1,047/month vs. $1,152/month. $105/month for a borrower with good credit score and solid employment history.
If that borrower would qualify for the same payment at a 65% LTV (in other words, if the borrower could qualify for the home if the loan was $214,500) how risky is using the hybrid, even when assuming it is off by 10% on the collateral value?
I would argue that it doesn't add much risk at all... excepting in the case where we have a significant market downturn, and then all bets are off anyway.

If you take that 10% over-valuation, and say 50% of all hybrid transactions appraised are going to be overvalued by 10%, then the payment difference (using the values and terms I outlined as an average) looks like this:
$1,047/month vs. $1,099/month. A difference of $52/month.
Certainly, if the borrower would qualify at the 10% over-valuation, and we assume that 50% of these transactions are over-valued to a potential of 10%, then the on-average 5% overvaluation isn't that significant in terms of the borrower's ability (based on credit and employment) to service that debt.

I think these are the kinds of macro-analyses that drive much of the decision-maker's evaluations of these products.
We are focused on the per-assignment valuation (me) and the larger impact on the policy of using such products (you). It isn't that those concerns aren't part of the lender/GSE's evaluation metrics. It is that they don't just stop at the value-component; they take that to the larger component of risk mitigation.

Lastly, I hope (probably in vain) that I won't be misquoted as saying I don't care about appraisal credibility or that it is perfectly alright to overvalue properties because the laws of large numbers, or the specific inputs I use, seem to argue that it doesn't matter. That's not what I am saying at all.
I am saying that in order to put limits on these types of products, it would be in our best interests to consider how the decision-makers who will determine their use and their breadth evaluate their risks.
 
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I A. Does the collateral value process (hybrid) match the risk of the mortgage-transaction or related transaction (portfolio monitoring of troubled assets) for the specific assignment?.
Appraisers don't risk score loans, or borrowers. Nice try though. Lenders don't even risk score loans or borrowers, or appraisals. Only
Fannie does that now for residential lending. And oh my, how hard is it to provide the appraiser with data and get a risk score of 2.5 or below?

IB. What is the SOW to complete the assignment?.
At a minimum, USPAP, which REQUIRES
recognition of, and compliance with, laws and regulations that apply to the appraiser or to the assignment. So where are these mystery regulations that apply to lending assignments that say a desktop appraisal is credible? All the written regulations fro lending say, no they are not sufficient. And both the lending regulation and USPAP 2-3, say appraisers can't have a bias that favors the cause of their client. No USPAP relief for a low LTV loan.

C. Can credible results be concluded (an appraiser's call to make) based on "B" and is the appraiser satisfied to the risk-assignment ("A")? And, BTW, some appraisers will make the presumption that a regulated lender has the wherewithal to determine that the risk-profile of the transaction it is requesting a hybrid to be completed for is appropriate. Obviously, depending on what physically exists or is discovered via the appraiser's or inspector's research may alter that conclusion... which, in some cases, it should..
The GSEs have no made any statement that bi-f appraisals are credible. The IAEG definition of credible requires evidence, which, without posting the links to your supposed program as acceptable, there isn't any evidence. The Dodd Frank requires higher priced mortgages to have interior inspections by the appraiser, yet no one is providing the price of the mortgage to the appraiser for the appraiser to even guess if it is a higher priced mortgage. So, where are your links?
D. Given all of the above, can they be done in a USPAP-compliant manner?
Not for residential lending.

E. If I say "yes" to "D", my final question is, am I going to get paid a price that I'm willing to take? If so, I'm considering taking these assignments. If not, they won't be part of my service offering..
And if your answer to D was no, why post a leading question, without posting the links that say bi-f appraisals are acceptable, so we can just get on with business. What's being hidden by not posting those links to the acceptable of bi-f appraisals?

All of the above are reasonable points to raise; especially by appraisers (but not limited to appraisers)

Sure, ask questions.
upload_2018-7-24_14-35-5.png
https://www.fanniemae.com/content/FAQ/appraiser-quality-monitoring-faqs.pdf

upload_2018-7-24_14-36-6.png

Updated monthly, by the way.

But so long as HAL is scoring your report, no one will ever know if you inspected the subject or the comps or not.

:coolsmiley:

That's why no one has it in writing, just in case "the public" finds out the lenders are feeding appraisers data, that the lenders aren't responsible for.

Did anyone read the WaMu, First American, EAppraiseit issue that Andy Cuomo had?


upload_2018-7-24_14-36-39.png
 
Appraisers don't risk score loans, or borrowers. Nice try though. Lenders don't even risk score loans or borrowers, or appraisals. Only
Fannie does that now for residential lending. And oh my, how hard is it to provide the appraiser with data and get a risk score of 2.5 or below?

In this case, I'll consider this a misunderstanding of the answer in the context to Envincere rather than a misrepresentation of what I said (the difference here is your intent).

Read Envincere's post about the reasonableness of appraisers asking questions about the hybrid product.
Then read my response (to which I agreed with Envincere). My point A which was premised as:
I liked this post and agree with it. It isn't unreasonable at all for anyone (in general) and appraisers (in particular) to challenge the appropriateness or prudence. As I've said over and over, we are stakeholders in the lending process (writ large) and are first-hand parties to the appraisal valuation....
...it detracts from the fundamental issues (as I see them) regarding these products, which I boil down to:
A. Does the collateral value process (hybrid) match the risk of the mortgage-transaction or related transaction (portfolio monitoring of troubled assets) for the specific assignment?

So I didn't say this was an appraiser issue. Again, I'll give you the benefit of the doubt that you simply misinterpreted it in its context.
I do say that as stakeholders in the lending process, we certainly have the ability to challenge the appropriateness or prudence of hybrids.

By the way, last time I checked, GSE transactions were exempt from the IAEG. Did that change?

Everything else you posted is not relevant as it doesn't cover the hybrid pilot program and for sure doesn't discuss what the proposals are for the hybrid if (and I think they will be) are rolled out.

However, to quote you:
Nice try though.
 
I do very few 2055/s and so do most appraisers ...( that I know) But yest I feel a bit more "exposed " to possible issues with 2055 forms. I did a few last year pre foreclosure for a client and found them more time consuming each time out digging for info, etc I stopped accepting them

And a 2055 is still not a hybrid desktop...appraisers are cranking them out in 45 minutes that's on them, but I am just wondering if any of the reports one day will be looked at more than these appraisers think.

Turn time/speed is very much a problem in these products and in fact of much of res lending work. Though it's understandable clients need/want it fast, many of the deadlines are AMC imposed to impress their clients/win market share and put pressure on appraiser and reduce time for verification, research etc. Appraisers are turning in reports faster than ever, typically 2 days after inspection.

The other pressure of course comes from the speed of data itself. An appraiser can't "compete" with the spit it out in seconds speed of data/software driven products such as AVM 's, but our performance is rushed to catch up with it


How much time/effort an appraiser spends on an assignment is within their own control, up to and including the rejection of unreasonable turn times. If appraisers are short sheeting their assignment requirements that's on them; not their clients and not the fee.

If the primary distinction between what appraisers do vs what the BPOs and AVMs do is the higher degree of data qualification and analyses then it stands to reason that we should be focusing our efforts on three aspects

- actually planning on doing the work
- so that we can assert the reasonable expectation
- and then proceed to meet those expectations

To whatever extent the lenders think that what they normally get amounts to the 45-min SOW - enough so to equate what they're now proposing to what they've been getting - then part of the blame for their perception rests with us. We either haven't been doing "more" or we've been doing it without making it sufficiently clear that we've been doing it.

Personally, I think the problem involves a little of both. Some appraisers have not been doing more; and some appraisers have been doing more but are not adequately tooting their own horn; thus leading to the lower expectation at the user level.
 
By the way, last time I checked, GSE transactions were exempt from the IAEG. Did that change?
:

Not to my knowledge, but when appraisers are not naming FHA or VA or USDA as intended users of residential lending appraisals, those are the remaining regulations that apply to residential lending appraisals.


Everything else you posted is not relevant as it doesn't cover the hybrid pilot program and for sure doesn't discuss what the proposals are for the hybrid if (and I think they will be) are rolled out. However, to quote you:

Of course it's relevant.

That's why none of you will post a link to this supposed hybrid pilot program.

What don't you want appraisers to see?

.
 
:ROFLMAO:

And no link to this "supposed" pilot program.

No announcement by the GSEs.

Oh but the next article is enlightening.

Ginnie Mae nominee deflects questions over GSE reform proposal

Again, where is the link from the GSEs about any pilot program?

The National Mortgage News is not a pass, for regulations that apply to the assignment.

.
 
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