Hybrid

[hastalavista]

Who is going to enforce it? Toothless rule...The license isn't going to arrest them. The client isn't going to monitor their work in any detail...

That's pretty much your answer to anything you disagree with: Licenses are worthless. Boards are useless. USPAP is useless. No one follows it, no one enforces it, etc., etc., etc.

With that outlook, nothing works and everything is suspect.

Hope I never get to that point.

 

[George Hatch]

We normally consider the "professional" work of an appraisal to come down to analyses, opinions and conclusions. Other functions can be completed by clerks but an "appraisal" is an opinion. Data entry can be done by anyone. Simply measuring and photographing can be done by anyone. The main gray area with a 3rd party inspection that I can see would be rating quality and condition; because those would often be characterized as opinions, not necessarily facts.

The cost breakdown submitted by a contractor isn't the same thing as a cost approach to value that appraisers do because we take those costs, add whatever profit or accrued losses there are and then reconcile for value. An Environmental report, or a Survey are reports that are generally completed by 3rd parties and although we would usually reference them in our reports we wouldn't usually consider those individuals to be providing appraisal assistance.

 

[George Hatch]

The primary mode of enforcement of any rule, regulation, guideline or policy is when the individual *chooses* on their own and in advance to be the good citizen and comply.


If you were to quantify the degree of compliance with a speed limit on a highway the main reason for that rate is because that's how many people choose in advance to comply, not because the cops were sufficiently effective to catch everyone who exceeded that limit. The cops will only catch the worst of the worst.

 

[timd354]

That's pretty much your answer to anything you disagree with: Licenses are worthless. Boards are useless. USPAP is useless. No one follows it, no one enforces it, etc., etc., etc.

With that outlook, nothing works and everything is suspect.

Hope I never get to that point.

....and get off Terrel's lawn!

 

[Meandering]

you guys love to make up stories.





The appraiser,

No somebody else who'll tell the appraiser.

https://files.consumerfinance.gov/f/201401_cfpb_tila-hpml_appraisal-rule-guide.pdf

 

[hastalavista]

you guys love to make up stories.

The appraiser,

No somebody else who'll tell the appraiser.

https://files.consumerfinance.gov/f/201401_cfpb_tila-hpml_appraisal-rule-guide.pdf

Well, glad to see you agree with me; since the reference is for Higher-Priced Mortgage Loans:


That is the kind of boundaries I'm talking about.

Although I might be more restrictive than you, since the document below lists those transactions that are not required to fall under the HPML

 

[DWiley]

https://www.consumerfinance.gov/ask-cfpb/what-is-a-higher-priced-mortgage-loan-en-1797/

A "hybrid" cannot be used with an HPML due to the inspection requirement. One also cannot be used (as of now) for an FHA or a VA. Not all types of appraisal can be used for all types of loans. Not exactly headline news. Hybrids have been around for over a decade, and they have never been able to be used for all types of loans.

 

[Meandering]

https://www.fanniemae.com/content/guide/selling/b4/1.1/05.html

 

[Meandering]

https://www.consumerfinance.gov/ask-cfpb/what-is-a-higher-priced-mortgage-loan-en-1797/

A "hybrid" cannot be used with an HPML due to the inspection requirement. One also cannot be used (as of now) for an FHA or a VA. Not all types of appraisal can be used for all types of loans. Not exactly headline news. Hybrids have been around for over a decade, and they have never been able to be used for all types of loans.

But since it is the appraiser who determines the scope of the work,

When is the "Qualified Mortgage" rating disclosed to the appraiser?

.

 

[timd354]

you guys love to make up stories.


View attachment 35714


The appraiser,

No somebody else who'll tell the appraiser.

https://files.consumerfinance.gov/f/201401_cfpb_tila-hpml_appraisal-rule-guide.pdf

Typical Marion red herring....Neither Fannie, Freddie, the VA or FHA purchases or secures loans that are HPML's, so this rule simply does not apply to the overwhelming majority of residential mortgage transactions. Additionally, the rules for HPML's only apply to closed-end (HELOC's are excluded) consumer credit transactions (meaning mortgages on primary residences only - not second home nor rental home mortgages are covered by the rule) and there is a small loan exemption of $26,000 which means any small first or second mortgage loan is not covered by the rule. Other exclusions from the rule include construction loans, bridge loans with a term of 12 months or less, , and reverse mortgages.

There are very few mortgage lenders that originate such loans and there is little doubt that these lenders are obtaining appraisals with an interior inspection in order to comply with the rule. Even if somehow one of the HPML lenders mistakenly orders a bifurcated or exterior only appraisal, that is the appraisers problem unless the lender informed the appraiser (or the appraiser somehow otherwise knows) that the report is being in done in conjunction with a HPML and that is the only appraisal the lender is obtaining (i.e., the lender is not also obtaining an apprasial with an interior inspection from another appraiser)