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Let The Borrower Pick The Appraiser

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GH and KenB both have excellent points.

Playing devils advocate as I do so often in support of public trust....,,

There is the matter of "fastest and cheapest".

That is where antitrust law comes into play imo. And it starts with market power on price due to market structure.
 
The other reason, and probably the biggest reason, is the lender's accountability for their use of the appraisal. The banking regs hold the lenders directly accountable not only for their use of the appraisals but also for their selection of the appraiser. As a practical matter the gov't can't hold the lenders accountable to this degree without giving the lenders the discretion to accept or reject. The further the lenders are able to distance themselves from these decisions the harder it becomes to hold them accountable for what they're actually doing.

From a regulatory standpoint, the use of appraisals is not intended to enable mortgage lending; it is intended to add an element of safe/sound to the lending decision as a means of offsetting risks. That means that a property that is valued too conservatively to enable a particular loan amount does not represent a threat to the gov't interest in safe/sound lending, and is therefore vastly preferable to an appraisal that is overvalued.


Moreover, the only intended use of these appraisals is to make mortgage decisions, and the only users of the appraisal that make those decisions are the lenders. That makes every other party in the transaction an off-label users, and every other use of the appraisal an off-label use.

So when a loan officer "uses" an appraisal (and an appraiser) their criteria for what is and isn't acceptable for that use is often in direct conflict with the use that's stated in the report. Same with the borrowers. These parties don't make the decisions towards which the appraisals are ostensibly aimed at, so if/when their interests are of effect on the results it is never aimed at promulgating the legitimate use of the appraisal within the context of its stated usage.

If all the action occurs at the margins it only takes a small percentage of bad appraisals to taint a loan portfolio. And IRL it takes a lot of performing assets to offset the loss from a single non-performing asset, particularly if that asset was grossly overvalued and consequently grossly overencumbered to begin with.

You have been on my brain lately. I was worried because I haven't heard from you lately. I missed you.
 
Personal fact:

The oligopsony with market power on price has driven many of the most respected and experienced appraisers from the market. How does that rhyme with what is best for the public?

No alternative facts on that now. :rof::rof::rof:
 
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Personal fact:

The oligopsony with market power on price has driven many of the most respected and experienced appraisers from the market. How does that rhyme with what is best for the public?

Real Fact: As long as those who remain meet the minimum standards in their appraisal process, by definition the public trust is maintained. :cool:

That doesn't mean I'm against providing services that exceed the minimum standards. This forum is like Lake Woebegone... everyone thinks their work is above average and I do too.:ROFLMAO:

Exceeding the minimum is a marketing differentiation.
Meeting the minimum is what is needed to protect the public trust.
 
Real Fact: As long as those who remain meet the minimum standards in their appraisal process, by definition the public trust is maintained. :cool:

That doesn't mean I'm against providing services that exceed the minimum standards. This forum is like Lake Woebegone... everyone thinks their work is above average and I do too.:ROFLMAO:

Exceeding the minimum is a marketing differentiation.
Meeting the minimum is what is needed to protect the public trust.

Fair enough and does price or qualifications enter in the selection? Or is it just fastest and cheapest? How does "minimum" equate? Don't think that if I am an AMC that controls a small percentage of your market, that I don't have some market power on price. Fastest and cheapest is bad for the profession, but an oligopsony don't care. It is a market structure that has no blood. No blood to bleed.
 
Meeting the minimum is what is needed to protect the public trust.

Based on some of the terrible appraisals I've come across in past year, which technically may have met the client's " minimum", but had awful comp choices and poorly supported values, I have to disagree. When minimum standards are in the hands of entities with an agenda of profit from skewing what constitutes minimum, the public trust is not at all protected.
 
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Meeting the minimum is what is needed to protect the public trust.

Based on some of the terrible appraisals I've come across in past year, which technically may have met the client's " minimum", but had awful comp choices and poorly supported values, I have to disagree. When minimum standards are in the hands of entities with an agenda of profit from skewing what constitutes minimum, the public trust is not at all protected.

An oligopsony don't care about public trust. It can't care because it is an economic entity with no brain or blood. Fastest and cheapest it cares about, but trust? No.
 
That doesn't mean I'm against providing services that exceed the minimum standards. This forum is like Lake Woebegone... everyone thinks their work is above average and I do too.:ROFLMAO:

Au contraire!!!!

Not everyone!!!!! :LOL:
 
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