RIP AQB and ASC, to be replaced with "Federal Valuation Agency"

[JTip]

While you read, you can listen.

 

[Terrel L. Shields]

What we will see is a huge shrinking of the appraisal participants, replaced by corporate appraisal firms, where only one or two signatures are in the house. It will be like a RE brokerage. The broker runs the show and the agents are basically permanent trainees without a license. This system might even replace the AMC as the firm will contract to a bank. Runners will inspect and value the house and the 'boss' - license holder - will review and sign the report. 90% desktop work. Little better than the AVM...in fact, may incorporate the AVM into the "brokerage". The runners will input all the data and office staff write the reports and the boss signs off after review.

 

[The Bob]

Who do you think this will apply to?

(2) DISCRETION TO DELETE OR MODIFY PUB2 LICLY AVAILABLE DATA.—The Director of the Bureau of Consumer Financial Protection may, at the Director’s discretion, delete or modify information collected under this section which is or will be available to the public, if the Director determines that the deletion or modification of the data would advance a privacy interest.

 

[djd09]

The runners will input all the data and office staff write the reports and the boss signs off after review.

one world appraising = craigslist inspection + avm + chief appraiser compliance signature

 

[CGinMN]

"There is a lot of discretion in how appraisers make their adjustments, how they choose comparable sales, and how they ultimately reconcile to the final value conclusion. We need to find ways to remove as much of that discretion as possible." - James Park, Executive Director of ASC

Coming from the only appraiser in the room, this floored me. Is Mr. Park's contention that the Federal government should regulate comparable selection criteria, adjustments, and the final reconciliation process? Shouldn't the goal be to give appraisers more information to make better-informed decisions rather than eliminate their ability to logic and reason through appraisal problems? Haven't we learned that user efforts to control these factors have unintended consequences that make appraisals less credible?

 

[djd09]

park is 'a joke'. the old white guy accusing other old white guys of unconscious bias. cant make this stuff up.

 

[George Hatch]

Just the fact that he got the sequence out of order is a problem. Most of the appraisal occurs in the comp selection. Not in the adjustments and not in the reconciliation.

As for discretion, I disagree with that characterization, too. Whenever a nominally sufficient amount of sales data are present, there are definite limitations as to what an appraiser can reasonably present as comparables in an appraisal report. We are required to certify to the comparability in the GSE forms:

7. I selected and used comparable sales that are locationally, physically, and functionally the most similar to the subject property.​

That's an assertion that can be sussed out as either being objectively true or objectively untrue, and its been in effect for every one of those appraisals for as long as I can remember. I have no objections to codifying it into federal law but that isn't going to improve the ability of the feds to enforce it because it's perfectly enforceable now. Same as with all the dramatics involving bias in an appraisal report. We've always been prohibited from doing everything that they're proposing to prohibit now.

 

[shrubberyvaluation]

"There is a lot of discretion in how appraisers make their adjustments, how they choose comparable sales, and how they ultimately reconcile to the final value conclusion. We need to find ways to remove as much of that discretion as possible." - James Park, Executive Director of ASC

Coming from the only appraiser in the room, this floored me. Is Mr. Park's contention that the Federal government should regulate comparable selection criteria, adjustments, and the final reconciliation process? Shouldn't the goal be to give appraisers more information to make better-informed decisions rather than eliminate their ability to logic and reason through appraisal problems? Haven't we learned that user efforts to control these factors have unintended consequences that make appraisals less credible?

I imagine that is why they picked that person to quote.

 

[shrubberyvaluation]

Just the fact that he got the sequence out of order is a problem. Most of the appraisal occurs in the comp selection. Not in the adjustments and not in the reconciliation.

As for discretion, I disagree with that characterization, too. Whenever a nominally sufficient amount of sales data are present, there are definite limitations as to what an appraiser can reasonably present as comparables in an appraisal report. We are required to certify to the comparability in the GSE forms:

7. I selected and used comparable sales that are locationally, physically, and functionally the most similar to the subject property.​

That's an assertion that can be sussed out as either being objectively true or objectively untrue, and its been in effect for every one of those appraisals for as long as I can remember. I have no objections to codifying it into federal law but that isn't going to improve the ability of the feds to enforce it because it's perfectly enforceable now. Same as with all the dramatics involving bias in an appraisal report. We've always been prohibited from doing everything that they're proposing to prohibit now.

That could be read subjectively too. What is locationally most similar? Is it that more proximate house in a completely different neighborhood? What if a home is further away from the subject but it is similar distance to where most jobs are with similar access to major roads? Who decides how to rank location, physical, and functionality. How can you objectively say whether an except replica of a house in a different neighborhood is better or worse than a less similar home in the subject's community. If both are used how can you objectively say what is best in the reconciliation?

 

[djd09]

it is the conspiracy of all conspiracies, appraiser colluding to select comparable sales to lower the values of certain areas