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My idea for a fix

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444nutman

Senior Member
Joined
Jun 20, 2007
Professional Status
Certified Residential Appraiser
State
Florida
I am happy with some of the Cuomo plan. The part I am worried about is who is assigning the work so I got an idea. The problem has been and always will be the lender has no recourse for a fraudelent appraiser. They dont have a dog in the hunt or have no worry about finding a skippy to get a number needed to make the loan. I have policed myself and dont want to lose good clients.
My proposal is Freddie/fannie pull 1 appraisal out of 50. They have another interior inspection made by another appriaser that can be on a list. The appraiser needs to be from the area in which the original appraisal was ordered. The appraiser can see if the hole in the roof was overlooked or that the comps used were actual comparbles or superior comps used to push the value. This gives skippy some chance of getting caught.
The reivew appraisal should focus on fraud. I don't think we need to have a witchunt for an appraiser who put none for gutter but their is acutally gutters. I am talking about taking all your comps from a superior subdivsion and ignoring comps on the same street. We all know what a pushed appraisal looks like.
This is the key part. When a fraudelent appraisal is found then that appraiser and the LENDER or AMC have to go in front of the board and explain their appraisal. Their needs to be penalties for the lender and appraiser. The first offense for the appraiser get fined and lender gets a warning. The second time the lender gets fined and the appraiser finds a new profession. Think about it the lender is going to look for appraiser who do a good job. They dont want to keep having to go in front of a board and explain how their UW let the appraisal go on to Freddie/Fannie. This will require diligence on the lender as well as the appraiser. The only solution should include the person that orders the appriasal as well as the apprasier. What does everyone think?
 
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44,

You are right that good quality reviews that are properly followed up are deterrents as well as chances to catch bad actors.

But that alone does not directly affect the lenders' behavior of abdicating their federally regulated obligation to assure appraiser independence.
 
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