New FNMA ROV requirement

[Amy Perkins]

if you have a wrong value, it is a misleading report...intentionally

 

[TerryRohrer]

I agree with the views of those who don't feel a short regurgitation of comments already in the report addressing the adequateness and criteria of the comparable sales selected for analysis in the report is the way to address an ROV, though it is always tempting when things are busy.


When a value comes in below the contract price, I anticipate some push back. Even knowing this, there is really no way to stop it, especially when it is initiated by an unhappy seller and their agent, and in recent times an unhappy borrower??. Even if the agents know the value is fair, they will not want to discourage their clients and will do their job and represent their interests.

What I try to do, and I probably take more time than I should because, luckily, I dont really see too many, is push back hard in a professional way to make sure they understand why their comps which are 50-60% larger, newer, and on better lots, ect, are not appropriate or not as appropriate as the comparable sales provided.

Recently, I had a realtor send over new construction comps for a 30 year old house in an established neighborhood with 6 similar sales in the past year, 3 of which were less than 90 days. They had 4 offers, the one accepted was 30k above the next highest (yes, i did ask for and receive the signed offers from the listing agent). How do you say outlier? The buyer's agent who submitted the offer also submitted an ROV according to the listing agent, but i never saw that one. House did settle at the appraised value, but I got a request to make comments on the new price/ addendum to the COS. It never ends.

Do you think the complainant is ever satisfied with your response? My only concern is that when all is said and done, I can defend my conclusions. I have no duty to educate an unintended user and they aren't going to take the time to understand the process and conclusions anyway. I almost never receive comparable sales, and if I do they are typically already in my work file. In my process, I can quickly drop any I haven't considered in the grid, adjust them to the subject, and then move them to my work file. When they support my conclusion, I add that to my response. When they would require a day of analysis to equate them to the subject, I dismiss them. By the time I deliver a report initially, I have earned my fee. I am not compelled to complete a second report for free simply in an attempt to make someone happy who never will be. But the bottom line is, there is no specific requirement I can find outlining requirements for the appraiser other than to address the request. I don't see a one size fits all response, but mine will be as efficient as can be.

 

[djd09]

they should of got a waiver...lowballers

 

[Zoe]

I think the point I'm driving at is to disprove the predictable pushback in the original report.

Now with a refinance it might be better to handle it on the front end like with the case in CA. I would. I would have asked those homeowners many questions on the front end. I would have never discussed appraised value with those people but I would have went down a 5 mile road wanting to know how they felt about the situation and why before I completed the refinance appraisal. I would have asked the couple that appeared before Chopra to share all they could about the prior financing they had on the rehab loan, etc, etc.

One of my last questions would have been which properties do you think compete most with this property? Where would you have moved if you didn't move here? You have spent a ton of money on this home. Can you share a list etc and answer a few more questions if I need you to?

If they wanted to share the prior appraised value before renovations with me, I would have been happy to absorb it.

 

[Zoe]

I don't appraise people. I appraise real property rights.

If they said we can give you a copy of the prior appraisal. We have it for you.

"Thank you for all you are willing to share with me.

It will help me in my appraisal for your lender."

Can you send it to me when you finish it?

"No, but your lender is required to. Your lender is my client. If they don't send it to you, then you need to request it."

Those were very intelligent people They would have melted like butter in my hands before I got through with them.

 

[Zoe]

If you smell smoke on the front end from the homeowner on a refinance, don't ignore the smoke if you can contact the homeowner for all the information you can get from the homeowner.

If you can't get it from the homeowner, ask your client to get it. The person with the gold makes the rules on a refinance.

 

[djd09]

Why Lenders Need To Watch Out for Appraisal Bias​

Justin Brown, David Larocque, Niall Twomey
12/2/2024
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Financial services organizations know they need to comply with fair lending laws when it comes to their in-house policies and procedures. But what many banks and other lenders might not realize is that activity outside their walls could represent a rapidly growing source of fair lending risk.
Fair lending regulators have recently ramped up scrutiny on one of the most common types of third-party vendors that mortgage lenders rely on: home appraisers. The regulatory and political dialogue around appraisal bias is gaining volume – quickly.

Appraisal bias, also known as home appraisal discrimination, happens when an appraiser assigns a lower value to a home because of the race of the people who own the home. Appraisers might also make value assumptions based on the racial makeup of facilities, businesses, and schools in the surrounding area.

Appraisal bias has become an increasing topic of scrutiny for regulators since 2021, when President Joe Biden announced the formation of the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE). PAVE’s mission is to investigate and root out racial and ethnic bias in home appraisals.

Not long after PAVE was established, a case involving a potentially biased appraisal drew national news headlines and even more regulatory attention to the issue.

In 2022, a Black couple in Baltimore claimed t

https://www.crowe.com/insights/why-lenders-need-to-watch-out-for-appraisal-bias

keep shooting down those ROV;s...let me know how that works out for you

 

[Sandra Koutsopoulos]

I just had the first ROV in ages for the smallest sized unit in a new condo development in a newly developing area in wine country. It was made clear to me after submitting the report, when the AMC mouthpiece said the lender was screaming mad, blah blah blah, they wanted a higher number, demanding it to be addressed immediately! RUSH RUSH RUSH! Due to the way the developer didn't record the individual sales in the complex, and only had a handful go through MLS, my database didn't find the individual sales, concessions, GLA, room count etc. So of 24 "comps" I shot photos of, when it came down to it, I could only verify 3 sales in the complex total, most of which had much larger GLA, plus newly built comps from outside the development 2 and 4 miles away. Meanwhile, every day, another 7-12 emails, text messages or phone calls over Thanksgiving & weekend to 'get them the number'. Right NOW!! They sent me several paragraphs from 2012 AQB or FNMA or someplace saying if something was typical (excessive buyer concessions in this case), I wasn't supposed to put the concessions on the grid. Then came the ROV with 4 more addresses and no verifiable info. Got together with title for verifications. Easily wasted another 4 hours of my time.

Unfortunately, they had also sent me a settlement sheet on a property showing they charged the borrower $700 for the appraisal. They weren't paying me anything close to that. Put me in a particularly ps$y mood, so I got to thinking, what with all the screams and drama etc. Yep, took photos of their new "comps", worked it up as additions on the grid. Only one of 4 brought them closer to "the number", and the rest were significantly worse than what I had already used. So I deleted my signature on the "appraiser independence" page and added some commentary to the ROV analysis, that I felt I was being coerced to 'hit the number' or lose future orders from the lender or AMC, that the value was the same as before all the drama. Oh, and BTW, payment for that appraisal was expected PROMPTLY!

Tried to upload the report through ACI, nope, it didn't like my commentary, noted it might be construed as meaning unfair lending practices or something.
What's a girl to do?! So I emailed a copy of the report XML & pdf to everyone at that company who had called, texted, or emailed me...
Didn't take long to get that phone call back. Seems suddenly my appraisal report was fine all along; dontcha know their head appraiser now said so. My status with that company is fine. They will have a chat with the ppl who harassed me.

The other thing is that consumers are still paying $700 to $1000 per appraisal to this company; govt apparently is allowing waivers to help reduce consumer costs; appraisers aren't paid $700/appraisal to provide unbiased valuations, and here this outfit is assuming we are their employees who they can bash around til they produce 'the number'. I don't play that. I told my husband, "I'm not leaving my profession, my professions is leaving me." Last one out, switch off the lights.

 

[Tom D]

No more than 2 yrs at most, I'll leave a note on the exit door for you. Sandra, switch off lights and don't let the door hit you on the a~~ on the way out. This is nothing compared to the new uad in 2 yrs. So, you get an rov once in a while, you understand the nature of our business. You can't fix stupid. You just do it and don't waste your inner energy on them. And feel good that they still look stupid with their request.

 

[djd09]

"We are considering including a section on reconsideration of value, and the fees entailed, in our Mortgage and Consumer policies. Can you share what stance or verbiage your institution is using? Have you made or considering making changes?
Thank you."

Reconsideration of Value

We are considering including a section on reconsideration of value, and the fees entailed, in our Mortgage and Consumer policies. Can you share what stance or verbiage your institution is using? Have you made or considering making changes? Thank you.

www.bankersonline.com

you cant charge...but the banksters can