Hybrid

[Michigan CG]

Thee are some things that are just facts. Yes it is somewhat about fees but the fee thing is still to be ironed out should these hybrid reports become more common. Some AMCs are simply lying about how long it takes stating "appraisers are completing these in 45 minutes". Well, maybe they are but an appraisal, short form or long form, still requires adherence to Standards 1 and 2. Fees will work themselves out over time and the majority of people charging $125 for a 1004D are not going to sign their name for $75.

I think that some people will have their cheese moved in a few years especially if congress gives FNMA what they want and it appears both sides of the political isle are willing to do that. A lot of people don't like what Danny is posting but he backs it all up with facts. Tim D is in the business and he backs up what he says with facts also. If you don't like it, maybe move on OR look to see where your industry could be in 10 years.

The people who will have their cheese moved are the ones who live in large metro area. There is just too much data to not have a lesser Scope of Work.

We can agree that the changing of USPAP every two years is just insane, especially this last one but the Scope of Work Rule was the greatest change ever (in my opinion) to USPAP (well that and getting rid of the Departure rule [which a saw a reference to in a report about two years ago]). Scope of Work in a very populated area where there are literally 50 recent sales is the appraiser's friend. What is more "accurate", an appraisal from a guy who can't find a matched pair to save his life and uses his $1,500 bathroom adjustment and $1,000/year adjustment or a database of thousands of sales in a general area? Do appraisers want to be eliminated from the huge population center work or adapt by taking advantage of Scope of Work?

We have to remember it is all about RISK. Is the $400 appraiser giving the lender less RISK than the computer at FNMA?

The cheese will move, it is a matter of time. What are appraisers going to do to prepare?

 

[Meandering]

If the message you got from Danny's post is that the fee situation relates directly in any way to the "non-compliant" line you've been running on this thread then that's a pretty dazzling interpretation of that paragraph.

LOL,

The "non-compliant" thing requires evidence of acceptability, which you still can't provide, without regard to anything Danny did, or did not say.

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[George Hatch]

If - as Danny says - hybrids have been used in the market for the last 10 years then somebody has obviously been accepting them. That much is self-evident.

You've pinning your non-compliant argument on the idea that appraisers might get hauled into court at some point in the future for performing assignments for clients whose regulators *actively* and knowingly allowed them to act that way. Openly and notoriously to the point that these products are being discussed at the ASC and TAF level.

At this point the idea that appraisers will be getting prosecuted for (according to you) violating banking law - which outside of cases of criminal fraud I'm not aware of any such prosecutions over the last 25 years - amounts to a red herring. If it hasn't happened yet then why would you assume it will happen in the future?

Like I said - not in evidence. You might as well be arguing that Santa Claus is wanted for burglary.

 

[Meandering]

If - as Danny says - hybrids have been used in the market for the last 10 years then somebody has obviously been accepting them. That much is self-evident.

You've pinning your non-compliant argument on the idea that appraisers might get hauled into court at some point in the future for performing assignments for clients whose regulators allowed them to act that way. Openly and notoriously to the point that these products are being discussed at the ASC and TAF level.

And the Fed let them issue NINJA loans to,
and when it all blew up,
The mortgage brokers were out of work,
yet Mortgage Brokers had no obligation to any regulation.
While Appraisers on the hand
have both USPAP and the IAEG
Oh and E&O insurance, let's not forget that..
And the IAEG says no EAs for condition.
But an EA is still necessary when using information that can not be verified, because USPAP requires it be verified by the appraiser, not by some unknown entity filtered through an interested party.

But keep spinning it.

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[Meandering]

If - as Danny says - hybrids have been used in the market for the last 10 years then somebody has obviously been accepting them. That much is self-evident..

Oh and just because "Danny says" is not evidence.

Danny also said, several times last month, that Section 1472 (C) of Dodd Frank was the "current law" when in fact it was only valid for 90 days in 2010 and was re-written in the IFR as called for in the Dodd Frank.

and within the past year Danny has claimed it costs more in Nashville to build a home that it does 30 miles down the road, but not due to any soft costs. It just does, because "he said so".

So no,
Danny's claims are not evidence of anything other than Danny's claims.

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[George Hatch]

With all due respect, the word "If" as used at the beginning of that sentence serves as a qualifier. Meaning I did not automatically assume Danny's comments to be the case even though I generally do consider his opinions to be credible.

But lets go back a sec. What if it is true that these have been around for a long time and EVERYONE involved at the regulatory level is aware of and has agreed to their usage? What happens then to your predictions of mass appraiser executions in 2025?

 

[DWiley]

And now everyone can see why there are so many threads about how these things are USPAP compliant, when it's evident, they are not, and they only exist to line pockets.
.

Give it up, George. Clearly, she is more versed on this topic than the certified USPAP instructors, the ASB itself, and the various state boards who have ruled on the matter. You need to just bow to her superiority

 

[Meandering]

With all due respect, the word "If" as used at the beginning of that sentence serves as a qualifier. Meaning I did not automatically assume Danny's comments to be the case even though I generally do consider his opinions to be credible.

But lets go back a sec. What if it is true that these have been around for a long time and EVERYONE involved at the regulatory level is aware of and has agreed to their usage? What happens then to your predictions of mass appraiser executions in 2025?

Again,
I'm not JGrant,
So I'm not going to play this, if then, else, game.

However.

FIRREA called for lending appraisals to be uniformed.
We got USPAP and Fannie forms.

Fannie is "considering them"
Hence they are not yet acceptable,
and,
they are not yet uniform, as required by FIRREA.

When Fannie decides they are acceptable, then you have an argument.

Until then it is a money grab that puts everyone at risk
with appraisers the least able to afford that risk.


.

 

[Meandering]

Give it up, George. Clearly, she is more versed on this topic than the certified USPAP instructors, the ASB itself, and the various state boards who have ruled on the matter. You need to just bow to her superiority

Yes,
because they were so quick to change the IAEG.

Got a new IAEG for the Dodd Frank.

Oh, but not for this issue.

Sham.

But you can still indemnify fee appraisers until Fannie makes a decision.

And you aint done that neither.

Keep spinning it.


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[DWiley]

Again,
I'm not JGrant,
So I'm not going to play this, if then, else, game.

However.

FIRREA called for lending appraisals to be uniformed.
We got USPAP and Fannie forms.

Fannie is "considering them"
Hence they are not yet acceptable,
and,
they are not yet uniform, as required by FIRREA.

When Fannie decides they are acceptable, then you have an argument.

Until then it is a money grab that puts everyone at risk
with appraisers the least able to afford that risk.


.

I have to say that you never cease to amaze me with the novel angles that you can come up with.

The "hybrid" process - someone other than the appraiser inspecting the home, either exterior only inspection or full interior inspection - has been reviewed by federal banking regulators and formally approved for use by lenders. That has happened multiple times, and it happened years before Fannie's current exploration of the process. Fannie's adoption of the process is not germane. I know this because several of the clients that we deal with did have questions about use of the process, and as a result of those questions they submitted formal requests to their regulators and did not implement the "hybrid" (really, modified desktop) process until their regulator told them, formally and in writing, that it was acceptable.

I do hope that you will forgive me if I accept the formal written opinion of the actual regulators over your personal interpretations.

As for the strict matter of USPAP compliance, given that USPAP has never required personal inspection of the subject property, any argument that the "hybrid" process is inherently non-compliant with USPAP is simply dead at the starting line.