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Maryland Commission versus Appraiser Bias

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George Hatch said:
it is in our own best interest to defend ourselves as best we can, starting with bomb-hardening our own workproduct.

You can only evade it by your opinion of market value being whatever the borrower wants when complaints are that you used comps from the subject's community.
 
What I think he's saying is, "ok fine, even if it's not racial bias, appraisers have a credibility problem when the spread between 2 valuations is $500k."
But is it when the property is multi-million dollar properties? I don't agree that we can always be within 5% of each other when dealing with a unique or large property with no cookie cutter comps to hang your hat on.

I am doing one. It has 2 duplexes, a 4000 SF house, extensively remodeled over its 40 yr history, a caretakers home, and 2 2 car garages, 19 acres, a boat dock and a swim dock with some 1000' of lake frontage with a great view...show me a cookie cutter to it.
 
I don't agree that we can always be within 5% of each other when dealing with a unique or large property with no cookie cutter comps to hang your hat on.
If the two values were $1.00mil and $1.05mil there’d be no accusation of bias.
 
So Fannie insists in their Selling Guide the following (the rules we have been under). So those who will be working for 30-years into the future, what criteria set forth by Fannie will you reject? Could the GSEs be the real racist after all?

"The appraiser’s analysis of a property must take into consideration all factors that have an effect
on value. The appraiser must analyze all closed sales, contract sales, and offerings or listings of
properties that are the most comparable to the subject property in order to identify any significant
differences or elements of comparison that could affect his or her opinion of value for the subject
property as of the effective date of the appraisal report. This is particularly important in changing
(increasing or declining values) markets. Analyzing closed sales, contract sales, and offerings
or listings is an important analysis in any market and will result in more accurate reporting on
market conditions, including trends that indicate that sale prices for contract sales and asking
prices for recent offerings or listings have changed. (Also see B4-1.3-03, Neighborhood Section
of the Appraisal Report, for information regarding Trend of Neighborhood Property Values,
Demand/Supply, and Marketing Time.)
..................
Part B, Origination Through Closing
Subpart 4, Underwriting Property
Chapter 1, Appraisal Requirements, Appraisal Report Assessment
April 15, 2014

Comparables that are significantly different from the subject property may be acceptable;
h
owever, the appraiser must describe the differences, consider these factors in the market value,
and provide an explanation justifying the use of the comparable(s).
Comparable sales from within the same neighborhood (including subdivision or project) as the
subject property should be used when possible. Sale activity from within the neighborhood is
the best indicator of value for properties in that neighborhood as sales prices of comparable
properties from the same location should reflect the same positive and negative location
characteristics.


Fannie Mae does allow for the use of comparable sales that are located in competing
neighborhoods, as these may simply be the best comparables available and the most appropriate
for the appraiser’s analysis. If this situation arises, the appraiser must not expand the
neighborhood boundaries just to encompass the comparables selected. The appraiser must
indicate the comparables are from a competing neighborhood and address any differences
that exist. The appraiser must also provide an explanation as to why he or she used the
specific comparable sales in the appraisal report and include a discussion of how a competing
neighborhood is comparable to the subject neighborhood.


Selection of Comparable Sales
The appraiser is responsible for determining which comparables are the best and most
appropriate for the assignment.
Fannie Mae expects the appraiser to account for all factors that
affect value when completing the analysis. Comparable sales should have similar physical and
legal characteristics when compared to the subject property. These characteristics include, but
are not limited to, site, room count, gross living area, style, and condition. This does not mean
that the comparable must be identical to the subject property, but it should be competitive ....

Unacceptable:

--failure to use comparable sales that are the most locationally and physically similar to the subject property;
--selection and use of inappropriate comparable sales;
--failure to comment on negative factors with respect to the subject neighborhood, the subject property, or proximity of the subject property to adverse influences;
 
So Fannie insists in their Selling Guide the following (the rules we have been under). So those who will be working for 30-years into the future, what criteria set forth by Fannie will you reject? Could the GSEs be the real racist after all?

"The appraiser’s analysis of a property must take into consideration all factors that have an effect
on value. The appraiser must analyze all closed sales, contract sales, and offerings or listings of
properties that are the most comparable to the subject property in order to identify any significant
differences or elements of comparison that could affect his or her opinion of value for the subject
property as of the effective date of the appraisal report. This is particularly important in changing
(increasing or declining values) markets. Analyzing closed sales, contract sales, and offerings
or listings is an important analysis in any market and will result in more accurate reporting on
market conditions, including trends that indicate that sale prices for contract sales and asking
prices for recent offerings or listings have changed. (Also see B4-1.3-03, Neighborhood Section
of the Appraisal Report, for information regarding Trend of Neighborhood Property Values,
Demand/Supply, and Marketing Time.)
..................
Part B, Origination Through Closing
Subpart 4, Underwriting Property
Chapter 1, Appraisal Requirements, Appraisal Report Assessment
April 15, 2014

Comparables that are significantly different from the subject property may be acceptable;
h
owever, the appraiser must describe the differences, consider these factors in the market value,
and provide an explanation justifying the use of the comparable(s).
Comparable sales from within the same neighborhood (including subdivision or project) as the
subject property should be used when possible. Sale activity from within the neighborhood is
the best indicator of value for properties in that neighborhood as sales prices of comparable
properties from the same location should reflect the same positive and negative location
characteristics.


Fannie Mae does allow for the use of comparable sales that are located in competing
neighborhoods, as these may simply be the best comparables available and the most appropriate
for the appraiser’s analysis. If this situation arises, the appraiser must not expand the
neighborhood boundaries just to encompass the comparables selected. The appraiser must
indicate the comparables are from a competing neighborhood and address any differences
that exist. The appraiser must also provide an explanation as to why he or she used the
specific comparable sales in the appraisal report and include a discussion of how a competing
neighborhood is comparable to the subject neighborhood.


Selection of Comparable Sales
The appraiser is responsible for determining which comparables are the best and most
appropriate for the assignment.
Fannie Mae expects the appraiser to account for all factors that
affect value when completing the analysis. Comparable sales should have similar physical and
legal characteristics when compared to the subject property. These characteristics include, but
are not limited to, site, room count, gross living area, style, and condition. This does not mean
that the comparable must be identical to the subject property, but it should be competitive ....

Unacceptable:

--failure to use comparable sales that are the most locationally and physically similar to the subject property;
--selection and use of inappropriate comparable sales;
--failure to comment on negative factors with respect to the subject neighborhood, the subject property, or proximity of the subject property to adverse influences;
--failure to use comparable sales that are the most locationally and physically similar to the subject property;

This isn't taking into account when the comps settled. The most similar locationally and physically may have sold a decade ago.

--selection and use of inappropriate comparable sales;

What is the meaning of an inappropriate comparable sale according to Fannie?
 
If they wanted to makes some targeted rules to address the potential issue they could say that appraisals in prince George's must be completed by appraisers that live in Prince George's.

This would trigger several things..

1) Appraisal fees would increase in Prince George's since there are relatively fewer appraisers there.

2) The higher fees and increase in demand for services from appraisers living in Prince George's may incentivize them to hire trainees who also must live in Prince George's.

3) This may result in increasing number of minority appraisers since majority of the people that live in Prince George's are minorities.

The obvious concern is that they go too far and make some kind of rule that says all appraisers can work in only the county they live in or something like that. But I think a targeted rule like that would increase diversity and give the homeowners more peace of mind about who is appraising their home.
 
See. I do not care about the 30 year behind you. I care about the 30 years in front of me and others around my age.

With all due respect, I think the best thing you guys can do is sit down and shut the **** up. :) You guys have no answers to the questions being asked of the profession and all you guys are doing is crying that you are not racist.

That is not an acceptable response.
If you knew any better, you'd actually consider others with more experience in appraisal and life in general to have something worth listening to. I am considerably younger than the average appraiser, likely younger than you too, so I'm not defending them because I'm in that group.

What I think he's saying is, "ok fine, even if it's not racial bias, appraisers have a credibility problem when the spread between 2 valuations is $500k."
Yes, credibility problem indeed, if in that example they were cookie-cutter. The owners of a local commercial property hired two appraisers to appraise a somewhat unique property. One was a local appraiser and the other appraiser was from further away. There was a major value difference between the two, with the one from further away being about 75% higher than the local appraiser. We've all seen things like this.

It is pretty obvious to me that it is probably caused by many appraisers not being familiar with the market as they should / could be.
I believe competency is the real underlying issue of these headline appraisals as well. One is familiar with the area and what would be considered truly "comparable" and one is not. THAT is an answer to the questions being asked, and it is a legitimate concern.
 
I think the idea that the homes in the community were appraised differently because they are black and live in a majority Black neighborhood is probably misguided but asking how many licensed appraisers in the state are African American is a fair question.
Hmmm... Quite a can of worms you're opening. So if the majority of the people living in the city are female, should the majority of the appraisers be female? Or if it is a retirement area, should the appraisers be old? How about bias of housing...
If the majority houses are twin homes, should the appraisers be living in twin homes. Or if it's in low rent area, should the appraisers live in a low rent area?

Bottom line. The appraiser should be judged on its report.
 
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