Hybrid

[Carnivore]

I think I have read a few times over objection about the SOW when it comes to the inspection for a desktop. True, the appraiser(per USPAP) makes the final decision of what is an adequate SOW for credible results. Even for Desktops. It is also true that Clients have a right to expand a SOW even when the Appraiser determines it is not necessary for credible results. I don't think i am wrong about either statement. Its not a dilemma as it may appear to be. You can always turn down the assignment.

My second point is the one where Marion brings up something about IAEG or whatever(it is) states some things that requires lenders to comply with on scope and other appraisal requirements etc, along with other things i suppose about lending.. OK, Maybe its true and it exist. What it does not do is saddle me, the appraiser. I am not required to follow that at all, unless a lender/Client stipulates what is outlined in my engagement letter.

This is why I am not opposed to Desktops. Yes, generally speaking they can be completed within USPAP. Can all of them be completed within USPAP. I cant possibly know because have not seen all the request. There are possibly many reasons why you cant, and just as many reasons why you can.

Example 1; I want to expand scope on a desktop assignment. Lender says sure as long as you meet turn time and we dont pay you anymore than we originally agreed to.

Example 2: Receive assignment, agree to fee, agree to SOW...send it in and lender now wants to expand SOW. No problem, just more money, plus I am not sure I can meet the new turn time here is what I need in time. Lender; You have to, Me NO! I don't this is a NEW assignment and I am busy. New Fee - Stalemate.

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OK this part is just my opinion and I have not checked with the State. Yet! But I will.

OK the next item is the Inspector. NC requires a Property Inspector to be licensed. Some said, 'well in the context of a Desktop. the inspector is just collecting data' via observation and putting that in writing. The inspector is also named in the Desktop Report. Bright people have said this is not significant assistance..

Lets look at a NC Licensed Property Inspector again I repeat per NC Law it states a property inspector must be licensed. So I suppose if one is used(I think they have to be used for a desktop in NC) then they should be identified in the report and they are IMHO Significant Assistance.

Now how can a Client/lender use a non-licensed property inspector(Harry the Scrap Metal guy) in a Desktop. Easy, NC law says they can do property inspections BUT Can not be compensated for that service. So as long as they are not paid then its OK and its not Significant Assistance.

This is peculiar to NC. and it maybe in other /states. Once the Big Banks and The Giant Gorilla's GSE's Throw some weight around to get NC Law Changed then its a dilemma(if it even exist).

But the Dilemma does not effect us Appraisers(unless we hired Harry the Scrap Metal Guy).

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Third and Final Point. I am just going to State something for you to seriously think about. Don't Devalue yourself this way when it comes to fee. The one part they don't have is the ability to analyse a market and Opine a Credible Market Value as of the Effective Date. Your the only expert in this Desktop Process. If a RE Broker is involved then Yes they are an Expert also, but they are Expert Advocates for the Property. Your not an Advocate You are NEVER an Advocate!

The higher a Broker sells it for the More Pay they Get..(or Lender mtg amount fee they receive). No matter what its Market value is you get the same Pre-Agreed upon Fee.

Please take a hard look at what you ARE WORTH. Don't fall for the Snake Oil Salesmen AMC or Lender/Client about the rich's you will make in one day.

Now Back to our regular scheduled Broadcast.

 

[Meandering]

So is that an argument of relevance to this thread? Do tell.

Most certainly.
It’s s “follow the money argument”, made to draw attention to the same reason the regulations are plainly written in the “queen’s English” yet, those who used to be highly respected appraisers now deny those regulations exist, or disavow them as not going to be enforced. And as I am sure you already know, yet refuse to share in your kool aid posts, lenders don’t sue appraisers. Lenders file SAR reports and the FBI and FDIC go after appraisers. Anyone can go to the FBI’s website and search the word appraiser and find all the same games that have been going on for years. Just because some call themselves AMCs, the games have not changed.

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[djd09]

It had already been 5-6 years since my most recent MB-engagement.
I had already held my CG for 7 years, and I was only appraising SFRs 1-2x per month; usually by direct engagement by regulated lenders or by attorneys
I had already been teaching USPAP and a dozen other CE topics to appraisers for 3 years. I was teaching 3-4 days a month. The USPAP/Laws combo days were 11 hours of instruction

Oh ok.

I lived and saw the biggest Mortgage Fraud case in the USA in 2009. True story. The BS meter is very sharp.

 

[George Hatch]

Why is it the appraiser always adapting to crooked lenders. Public trust?

Because we sell a due diligence service. The most we can do for our clients' bottom line is save them from a grievously bad decision. We can't actually make them any money. That's why, from their perspective, "save them from a really bad decision" is all the competent we need to be.

 

[djd09]

A Beachwood man has been accused of orchestrating what officials say is the largest mortgage fraud scheme in the history of Ohio and possibly the entire country.

Uri Gofman, 36, was indicted by a Cuyahoga County grand jury along with 40 people and four companies in a conspiracy prosecutors say involved 453 homes in Cuyahoga County and $44 million in fraudulent loans.

http://blog.cleveland.com/metro/2009/08/41_people_indicted_in_44_milli.html

Uri Gofman would love hybrids. Where were the regulators then. But now they know better. sure

 

[George Hatch]

Most certainly.
It’s s “follow the money argument”, made to draw attention to the same reason the regulations are plainly written in the “queen’s English” yet, those who used to be highly respected appraisers now deny those regulations exist, or disavow them as not going to be enforced. And as I am sure you already know, yet refuse to share in your kool aid posts, lenders don’t sue appraisers. Lenders file SAR reports and the FBI and FDIC go after appraisers. Anyone can go to the FBI’s website and search the word appraiser and find all the same games that have been going on for years. Just because some call themselves AMCs, the games have not changed.

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The manner in which the regulations are administered occurs prior to any enforcement actions. If you think it's illegal for the lenders to use hybrids then your beef is with how the regulators are administering the regs. Personally, I think you're incorrect but IRL it makes no difference what I think. The regulators and the lenders are doing what they do.

If a lender is allowed to order a hybrid from an appraiser then an appraiser can perform the assignment. If a lender isn't allowed to order a hybrid or isn't allowed to use it then they are the ones who are on the hook for it. \

As for the appraisers, we are regulated by our respective states. The FBI is a law enforcement agency that goes after criminal conduct, which would be a yuuuge stretch for you to characterize of an appraiser accepting and performing a hybrid. The FDIC and other banking regulators regulate the lenders and make referrals to the states - which I have only seen occur in the case of alleged fraud.

So you let me know when we get to referring to performing a hybrid is a criminal offense.

And FTR, I've never performed an appraisal for an AMC, I've never taken a referral from an AMC and I've never earned a dime from an AMC. So if you intend to imply otherwise I'm going to expect you to support your accusation.

 

[djd09]

More of the same, client wants, client needs, client dictates, client huge profits. That is the opposite of independent, impartial, and not bias. That is what happens when you let them rule make.

 

[Joe Flacco]

I don't understand what the confusion is. A hybrid is just a desktop appraisal.

 

[Meandering]

My second point is the one where Marion brings up something about IAEG or whatever(it is) states some things that requires lenders to comply with on scope and other appraisal requirements etc, along with other things i suppose about lending.. OK, Maybe its true and it exist. What it does not do is saddle me, the appraiser. I am not required to follow that at all, unless a lender/Client stipulates what is outlined in my engagement letter..

Sadly,

You are not the only one in this "I have no clue about the regulations that apply to the assignment.

So see if you can follow the USPAP about why you need to know what the IAEG is and what it says.


IAEG = Interagency Appraisal and Evaluation Guidelines
https://www.FDIC.gov/regulations/laws/rules/5000-4800.html

I. Purpose

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of Thrift Supervision (OTS), and the National Credit Union Administration (NCUA) (the Agencies) are jointly issuing these Interagency Appraisal and Evaluation Guidelines (Guidelines), which supersede the 1994 Interagency Appraisal and Evaluation Guidelines. These Guidelines, including their appendices, address supervisory matters relating to real estate appraisals and evaluations used to support real estate-related financial transactions.1

1These Guidelines pertain to all real estate-related financial transactions originated or purchased by a regulated institution or its operating subsidiary for its own portfolio or as assets held for sale, including activities of commercial and residential real estate mortgage operations, capital markets groups, and asset securitization and sales units.

I HOPE appraisers aren't certifying to competency and have never read the IAEG.

Dang.

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[Meandering]

I don't understand what the confusion is. A hybrid is just a desktop appraisal.

No it is not.

If it were just a desktop appraisal, only the appraiser would be involved.

the bi-f appraisal is a direct bias of the appraiser to rely on information provided by an interested party, while excluding the appraiser from performing the inspection themselves to gather their own data for analysis.

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