No bias here - keep moving

[TerryRohrer]

Definitive numbers are difficult to come by since the Department of Housing and Urban Development (HUD) has failed to respond to public record requests on this question. However, Working RE’s “off-the-record” conversations with HUD officials, plus our own experience at OREP Insurance serving over 10,000 appraisers with E&O insurance every year, has given us an inside look into what has otherwise been an obfuscated prosecutorial process for appraisers.

OREP and Working RE estimate that over 300 complaints alleging appraisal discrimination have been filed against appraisers with HUD—just in the last three years.

Craig Capilla, Partner at Franklin, Greenswag, Channon & Capilla, LLC and an attorney on the frontlines of defending appraisers, reports that he is personally handling over 20 HUD appraisal discrimination complaints that are all still open, pending matters. “After the initial interviews and document requests, there has been no action whatsoever. None have been dismissed and no determination has been made in favor or against any of my clients. Unlike a typical fair housing violation, such as rental discrimination, which can normally be vetted and addressed at the regional level, valuation-related complaints appear to be being handled differently. It feels like regional offices don’t have the authority or the discretion to make determinations. All the valuation complaints are being sent to the Washington D.C. office. The D.C. office is taking the lead on these,” advises Capilla.

https://www.workingre.com/HUD-discrimination-complaints-skyrocket/

 

[George Hatch]

The first thing that comes to mind is the possibility that HUD isn't finding what they might have initially expected to find. I can't imagine why they would sit on the results of their investigation on the issue if they were finding a lot of offenses.

 

[TerryRohrer]

Assuming the complaints under discussion are Fair Housing violations:

180 Days - To Investigate in an EEO Complaint In a Timely Manner
The agency is required to investigate the complaint in a timely manner. The investigation must be appropriate, impartial, and completed within 180 days of filing the complaint The EEO Director or designee and the complainant may agree in writing, consistent with 29 C.F.R. § 1614.108(e), to an extension of not more than ninety (90) days; or within the period of time set forth in 29 C.F.R. §§ 1614.108(e) or 1614.606 if there are multiple complainants with similar allegations of discrimination or complainant has filed multiple complaints which the agency has consolidated. If the agency fails to complete the investigation in 180 days, it shall issue written notice to complainant informing the complainant that it was unable to complete the investigation, the estimated date of completion, and complainant's right to file a civil action or request a hearing. See 29 C.F.R. § 1614.108(g). Agencies are required to complete investigations within the earlier of 180 days after the filing of the last complaint or 360 days after the filing of the original complaint. Regardless of amendment or consolidation of complaints, the investigation shall be complete in not more than 360 days, unless there is a written extension of not more than 90 days.

An investigation is deemed completed when the report of the investigation is served on the complainant in conjunction with the notice of the right to elect either a hearing before a Commission Administrative Judge or a final decision from the agency pursuant to 29 C.F.R. § 1614.108(f).

https://www.HUD.gov/program_offices...equired to,writing, consistent with 29 C.F.R.

 

[Non Sequitur]

The snippet below is from the Q4 Fannie Appraiser Update. Based on their take, it would seem that about 90% plus of the folks on this forum (as well as the appraisal industry in general) are fairly incompetent... while I'm actually one of those who believe credible results can be extracted through alternative SOW products, I nonetheless think this is below the belt for the GSE's to try to shame appraisers into changing their minds.

View attachment 94795

SOP for them. Radke has been touring the country this past year with his slide show making the case for rouge appraisers. I wanted to ask him "Why not point out the AMCs involved?" after he paraded his slides showing scofflaw appraisers completing an impossible number of reports in multiple states. He wasn't taking questions, imagine that.

 

[Non Sequitur]

The snippet below is from the Q4 Fannie Appraiser Update. Based on their take, it would seem that about 90% plus of the folks on this forum (as well as the appraisal industry in general) are fairly incompetent... while I'm actually one of those who believe credible results can be extracted through alternative SOW products, I nonetheless think this is below the belt for the GSE's to try to shame appraisers into changing their minds.

View attachment 94795

And one other point about the supposed profitability. He and many other chief appraisers/valuation managers, etc. keep pushing that narrative BUT run in the other direction when anyone points out the real fees being paid for hybrids, and the fees are crap. They talk about profits and how great the money is but hide behind the FTC when actual fees are brought up.

 

[shrubberyvaluation]

SOP for them. Radke has been touring the country this past year with his slide show making the case for rouge appraisers. I wanted to ask him "Why not point out the AMCs involved?" after he paraded his slides showing scofflaw appraisers completing an impossible number of reports in multiple states. He wasn't taking questions, imagine that.

But arn't those the most experienced appraisers doing hybrids, why is his berating them?

 

[alebrewer]

And one other point about the supposed profitability. He and many other chief appraisers/valuation managers, etc. keep pushing that narrative BUT run in the other direction when anyone points out the real fees being paid for hybrids, and the fees are crap. They talk about profits and how great the money is but hide behind the FTC when actual fees are brought up.

fully agreed. IMO, they could have EASILY gotten their point across without crapping on the folks who don't want to engage this product. For instance, the following would have been MUCH more palatable:

The unfamiliar: those who either: (1) have made a conscious decision not to research/engage in hybrids and desktops, or (2) haven't heard of the hybrid/desktop products

The skeptics: those who believe they cannot develop credible results given the restricted SOW

The fans: those who believe they can produce credible results given the restricted SOW and are building this product into their offering matrix


As an aside, I am one of the few in the 'fan' camp. But after reading that Q4 update, I'm in the Fannie hater camp. How that got past however many folks have to sign off prior to those updates being published is beyond me. It's ok for them not to be (as GH says) 'appraiser advocates', but it's not ok to take a dump on the folks that feed the machine.

 

[Non Sequitur]

But arn't those the most experienced appraisers doing hybrids, why is his berating them?

He’s claiming they found several appraisers completing ridiculous amount of reports daily with no assistance, not hybrids but 1004 reports. What no one ever points out is that if true, there’s no way an independent appraiser hustled up that kind of business, AMC‘s had to be involved and kept a blind eye to it. I’m not saying they shouldn’t look for that and sting appraisers doing that, they also should sting the AMC‘s and appraisal firms involved.

 

[shrubberyvaluation]

fully agreed. IMO, they could have EASILY gotten their point across without crapping on the folks who don't want to engage this product. For instance, the following would have been MUCH more palatable:

The unfamiliar: those who either: (1) have made a conscious decision not to research/engage in hybrids and desktops, or (2) haven't heard of the hybrid/desktop products

The skeptics: those who believe they cannot develop credible results given the restricted SOW

The fans: those who believe they can produce credible results given the restricted SOW and are building this product into their offering matrix


As an aside, I am one of the few in the 'fan' camp. But after reading that Q4 update, I'm in the Fannie hater camp. How that got past however many folks have to sign off prior to those updates being published is beyond me. It's ok for them not to be (as GH says) 'appraiser advocates', but it's not ok to take a dump on the folks that feed the machine.

I just don't see the point. You have two people that don't know each other relaying information to the other. One has no liability and no incentive to do a thorough job, the other has all the liability. So you pay two people.

Is it because you have a 2nd chance with a full appraisal if it comes in below contract price? Is it for fradulent purposes? Perhaps get a friendly person to look at the property who won't want to show defects? I know companies won't use appraisers for the first part of the hybrid typically.

Can you imagine doctors having random people doing house calls for regular checkup that have no connection to the doctor, a quick training on themselves, and its more work for them if there is something wrong with the patient, if the patient dies because of a misdiagnosis all the liability goes to the doctor. Yea that is what the most experienced and trained doctors do. Send out a doctor's assistant that works for the doctor to speed up the process and help patients...can't do that though, we need a random person.

What is the necessity of this product in their offering matrix?

 

[TerryRohrer]

he paraded his slides showing scofflaw appraisers completing an impossible number of reports in multiple states. He wasn't taking questions, imagine that.

Why haven't they objected to those circumstances at any time during the past 30 years, I wonder. Not like their existence is a surprise to anyone who has been awake.