Rebuttal as a Service

[Recounts]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

 

[shrubberyvaluation]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

1. Not sure what you mean by legitimate. Simply forwarding without vetting the information from someone who is not an intended user and has a financial interest comes off as value pressure.

2. Why would you want someone who is not licensed? Perhaps because they have no liability for a bad review and you can pressure them to play ball.

3. I can count it on my fingers and its never been anything significant. I do a good job, I believe these happened when I was given market data that was not available in the normal course of business or something similar. If I ever mess up in the future I'm happy to change it, most rebuttals are just finding the highest sales or ones that they think will make it work regardless of their location or how similar they are.

 

[TerryRohrer]

Unfortunately, if it comes from the lender you should address it, though most are prepared and pushed by agents. If the rebuttal goes beyond providing sales to consider, and gets into a critique of your report, it could be argued it is a review and that party should be licensed. But, only you will probably care. I would not address more than the comps.

 

[Gobears81]

On #1, be sure to distinguish between the lender - which I'm assuming is the client in your case - and the borrower. It would have to be directed from the client/intended user for you to address anything.
I always welcome discussion and questions for my appraisals. Even with my best efforts to explain throughout the report, sections of the appraisal will frequently be misunderstood. But if they bring up issues that are correct, then why wouldnt we change our report? I would rather get it right the second time

 

[Amy Perkins]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

1. Yes. 2. No 3. No, not unless there is some reason like an error in the software, typo, or new information that I could not have known. Do your appraisal carefully, the value needs to be right.

 

[jay trotta]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

Just a snippet here;
FNMA ML 2015-02 clearly states: "Before asking the appraiser to consider any alternative sales, it is imperative that the lender analyze the relevance of the sale and determine if the use of such sale would result in any material change to the appraisal report".

So my question is, has the Lender performed their due diligence?? Can they provide support (IE: per FNMA requirement?)
In most instances and IMO I don't believe any Lender actually performs the noted analysis prior to issuing a rebuttal and therefore, no change(s) are needed/required.

 

[sputnam]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

1- Anyone can have an opinion about anything. Someone who has expertise is considered to have a more useful/valid opinion. Legitmate? Not sure what you are thinking there.

2- If you the rebuttal to be taken seriously, they should be licensed/certified.

3- I think maybe once.. in 37 years... and it was an issue of rounding up instead of down on the final value based on one comparable sale that I missed. Every Reconsideration of Value I've had, no new data was provided and there were no errors in the report. That's the only basis for a reconsideration. Either the appraiser missed some relevant data... or... they made significant errors in anlysis and/or reporting. The value.. which would be the most common reason for a dispute... is an opinion. Opinions are never wrong. They are more or less valid. You can agree or disagree with an opinion. At the end of the day, opinions are not facts.

No one can change the appraisal except the appraiser. Undue pressure on the appraiser from the Lender violates regulations. The Reconsideration of Value has to be transmitted by the appraiser's Client. I don't think there is any market for the business model you are considering.

 

[shrubberyvaluation]

1- Anyone can have an opinion about anything. Someone who has expertise is considered to have a more useful/valid opinion. Legitmate? Not sure what you are thinking there.

2- If you the rebuttal to be taken seriously, they should be licensed/certified.

3- I think maybe once.. in 37 years... and it was an issue of rounding up instead of down on the final value based on one comparable sale that I missed. Every Reconsideration of Value I've had, no new data was provided and there were no errors in the report. That's the only basis for a reconsideration. Either the appraiser missed some relevant data... or... they made significant errors in anlysis and/or reporting. The value.. which would be the most common reason for a dispute... is an opinion. Opinions are never wrong. They are more or less valid. You can agree or disagree with an opinion. At the end of the day, opinions are not facts.

No one can change the appraisal except the appraiser. Undue pressure on the appraiser from the Lender violates regulations. The Reconsideration of Value has to be transmitted by the appraiser's Client. I don't think there is any market for the business model you are considering.

There may be a market for it with AMCs if you are willing to take minimum wage was do whatever they tell you to do, but they would prefer someone certified to make their pressure look more legitimate given its the same price of minimum wage or close to it.

 

[Kitarkus]

I have a few questions:

1) If a rebuttal is written by a third party that is NOT the intended user or borrower, but the rebuttal is delivered by the lender/borrower, is it legitimate?

2) If somebody offered appraisal disputes/rebuttals as a service, does it have to be performed by somebody who is licensed?

3) Has a rebuttal ever resulted in you changing your value opinion? If it has, why?

Thank you in advance.

(1) Sure why not
(2) No
(3) Yes....but rarely....and only when some credible and verifiable information was presented which had been previously unavailable or overlooked by Appraiser

The real issue is that seemingly every Borrower whose appraisal concluded a lower than expected opinion of market value wishes to contest that value. Their 'rebuttal' or request for reconsideration inevitably exhibits a near complete lack of understanding of the Appraiser's processes. Worse yet, Borrower or Lender suggestions often and clearly exhibit 'target shooting' motivations without any credibility. A simple recent example: I had 12 identical comparable sales of C1 newly constructed townhouses. Subject backed to a busy road and was an end unit. I utilized all end unit dwellings which suffered from an adverse external influence....all sold within the recent 90 days. Rebuttal(s) came relentlessly with attempts to show the Appraiser sales which occurred up to 1 year prior of varying plan configurations....all superior....all older sales....all larger sales. There is a 'belief' among Borrowers and even among Lenders that any/all data is equivalent. Borrowers/Lenders don't understand the term 'final reconciliation' and have become so accustomed to 'rubber stamper' appraisers that they are nearly shocked to see an opinion of market value which falls below their threshold. I often hear "how far out can I go?" or "how far back in time can I go?" or "can I use this?" or "can I use that?". There is no trick to this.....The Appraiser is to credibly utilize the most recent, relevant, and directly competing comparable sales. If the Appraiser does not utilize the most recent, relevant, and credible comparable sales there had better be a good explanation for it. Seeking a higher value conclusion so that a 'deal gets done' is not a good explanation.

Assuming that the Appraiser did his/her job credibly....the typical rebuttal/ROI is driven largely by Borrower's emotion...and having little/nothing to do with the Appraiser's report. It is the Appraiser's job to remove emotion from the process(es). A credible rebuttal should exhibit that the Appraiser did NOT utilize the most recent, proximate, and directly relevant sales...or that they adjusted those sales inappropriately...or reconciled the final value conclusion inappropriately. In my years of experiences working in this business, when an Appraiser did NOT utilize the most directly relevant sales he/she had been already and inappropriately advocating on behalf of a Borrower or Lender....and I assume that these Reports do not receive rebuttals. When an Appraiser DOES THE JOB correctly and credibly we often see rebuttals with no merit.....because....well.....the job was completed and reconciled credibly the first time.

Aside from being a professional Appraiser....I can think of few more thank-less careers than the one you are suggesting as a Professional Rebuttal-ist lol.