Revision Request

[George Hatch]

If you are unable to articulate the improper if/then contingency then your convoluted prison logic falls apart. Without the improper result being articulated all that remains is the garden variety assignment condition, same as a request to comment on HBU or REL.

An example would be "If you'll increase the value we'll pay you for this assignment". Or, "here are some comps that will support our target value - please swap your comps out for these so we can get our deal."

You don't have that, and you know you don't have that or anything like that. There's no inducement for the appraiser to act as the advocate for the deal. All you have is a borrower who thinks these are better comps.

 

[Terrel L. Shields]

Basically TAF speak with formed tongue, do as requested, ignore the stone tablets...until we decide to come after you. Again, the ROV's purpose is to punish the appraiser for not hitting the number, nothing more. Otherwise, ROV's would be asked when you value the property above the contract or target amount. Show me such a ROV.

 

[hastalavista]

Otherwise, ROV's would be asked when you value the property above the contract or target amount. Show me such a ROV.

Values that appear higher than supported in the report get questioned all the time by a stakeholder.
New data is provided to the appraiser; or additional data is requested from the appraiser... and sometimes support for the adjustments applied is requested. All after the report is complete. It is the same or even more than what is asked for in an ROV.
Except we usually call this a review or an underwriter condition/stip.

 

[DTB]

Values that appear higher than supported in the report get questioned all the time by a stakeholder.
New data is provided to the appraiser; or additional data is requested from the appraiser... and sometimes support for the adjustments applied is requested. All after the report is complete. It is the same or even more than what is asked for in an ROV.
Except we usually call this a review or an underwriter condition/stip.

I completed 3,500+ appraisals, never saw such a request.

 

[Meandering]

If you are unable to articulate the improper if/then contingency then your convoluted prison logic falls apart. Without the improper result being articulated all that remains is the garden variety assignment condition, same as a request to comment on HBU or REL.

An example would be "If you'll increase the value we'll pay you for this assignment". Or, "here are some comps that will support our target value - please swap your comps out for these so we can get our deal."

You don't have that, and you know you don't have that or anything like that. There's no inducement for the appraiser to act as the advocate for the deal. All you have is a borrower who thinks these are better comps.

Values that appear higher than supported in the report get questioned all the time by a stakeholder.
New data is provided to the appraiser; or additional data is requested from the appraiser... and sometimes support for the adjustments applied is requested. All after the report is complete. It is the same or even more than what is asked for in an ROV.
Except we usually call this a review or an underwriter condition/stip.

Dancing ot Gladys's song,
all by yourselves.

.

 

[Meandering]

Selling Guide Announcement SEL-2018-01


January 30, 2018


Second Appraisals


We updated the Guide to clarify our policy on second appraisals. Currently, if a lender obtains a second appraisal, they must use that appraisal for the transaction. Going forward, the lender must document the deficiencies that are the basis for ordering a new appraisal and must select the most reliable appraisal, rather than always using the second appraisal or the one with the highest value.

This clarification more clearly aligns the requirements for second appraisals in the Selling Guide with the requirements contained in the Appraiser Independence Requirements and in the lnteragency Appraisal Guidelines. These clarifications are designed to simplify lenders’ processes and provide greater consistency with other secondary market investors.

Effective Date

Lenders may take advantage of this update immediately.


https://www.fanniemae.com/content/announcement/sel1801.pdf

 

[DWiley]

Otherwise, ROV's would be asked when you value the property above the contract or target amount. Show me such a ROV.

I have seen many ROvs that fall into that category. It is a common occurrence when one of the GSE underwriting tools flags a report for potential over valuation.

 

[Carnivore]

Has anyone ever received lower sold comps than used in a sale appraisal?

No..yes sort of...I have received a list of sales yanked from a area out of GIS, apprx 18-22(cant recall exactly.. That's all it was a list of sales. It was apparent to me that they were challenging my conclusions, simply because they were an interested party. My first reaction was geez what a pita. The list was fairly long. Some were in MLS, most were not. The kicker in the list was 7-8 of the sales were all part of a package sale. County GIS workers took total price paid and divided it equally between the 6-7 sale. Another kicker in the list were the comparable i had used.

My response was thorough and respectful. What I did in the response was shine light back at them. The response was several paragraphs. In the end they shut up because they had to know their little tactic of harassing me failed. I rarely do this, but i ask them in the future to be more professional in their approach to these matters. I pointed out to them that it is important to cull out the sales from their list of sale(s) I had already used in the original report.

There is no easy answer to ROV. It part of our life dealing with people who don't know as much as we do. Gone are the days of speaking with an Actual Underwriter. Fast & Cheap is the business model they all operate under. They want fast n Cheap Appraisers, They employ people who don't have years of experience in mortgage lending. Realtor are egotistical! They are always right and you are always wrong except when you agree with them.

The easiest way to deal with ROV is try to anticipate this as a normal course of events in the appraisal profession. In other words anticipate and address the potential issues/questions a reader/user of your original report. Its far easier to do that then to re-open a delivered report.

 

[Carnivore]

Is the VA's Tidewater protocol exempt from TILA?

Denis, I don't complete any VA work but I would assume that it is...OTOH this is a close knit group...and they have specific goals that rise above the noise of typical mortgage lending/Realtor crowd.

So by the way they operate whether they are exempt or not, probably does not matter to them. Their good at what they do and VA appraisers are held to high VA standards. Frankly I have never heard a VA Panel appraiser complain. Its a coveted list to be on and these guys and gals don't let the VA down.

 

[timd354]

Denis, I don't complete any VA work but I would assume that it is...OTOH this is a close knit group...and they have specific goals that rise above the noise of typical mortgage lending/Realtor crowd.

So by the way they operate whether they are exempt or not, probably does not matter to them. Their good at what they do and VA appraisers are held to high VA standards. Frankly I have never heard a VA Panel appraiser complain. Its a coveted list to be on and these guys and gals don't let the VA down.

No, VA does not have an exemption from TILA. Thus, if one is going to argue that Tidewater (which is nothing more than an ROV done earlier in the process) complies with TILA, then one cannot make a logical argument that a ROV on a conventional mortgage loan violates TILA. Of course, logic is a foreign concept to some of the posters on the AF.