TAF head Calls Jonathan Miller a Liar

[George Hatch]

I'm not talking about him, per se. Just the implications that

a) there actually is a significant appraiser misconduct problem WRT racial bias (and not any other weakness in the analysis)
b) that "representation" will cure that problem in those appraisals
c) that anything happening at TAF could prevent appraiser misconduct WRT to the established prohibitions of such which are already on the books
d) that "trainee" is a derogatory licensing category denoting anything other than the individual's lack of qualification to operate solo
e) that the profession should apparently consider cutting trainees loose once they take the QE and pass the test.

Of the above, the only one I agree MAY be a possibility is "a". There may or may not be a significant problem with appraiser misconduct. The number of ALL appraisal-related complaints (not limited to racial bias oriented) to HUD don't support that allegation and neither does the mere existence of a 2nd appraisal wherein the 2nd appraiser will mostly likely have been given the heads up. But until we see who is doing what and how they're doing it, all anyone has been doing so far is using the outcomes to back into the previously alleged cause of those outcomes.

In other words, both sides are using

Innocent/Guilty-by-we-backed-into-it​

which means that neither side is accepting the results of that methodology when its outcome conflicts with their own "I-backed-into-it" conclusions.

 

[Non Sequitur]

The only DEI fix TAF can do is eliminate the experience criteria for minority applicants (only), whilst retaining it for everyone else. Otherwise opening the floodgates for no-experience licensees will let in too many non-minority applicants to result in the desired racial quotas.

Yep, I can see that coming.

Remember, PAREA and MPAT were sold as a way to bring in minorities/POC because current appraisers were refusing to train them. Now here we are, surprise-surprise there wasn't a line of minorities just waiting for their chance. Add to that, for the few who do want to get in, PAREA isn't working because the AI thinks they are training neurosurgeons and MPAT down in Mississippi is, well, typical Mississippi. Moving on to the next step, the only way to get the numbers they want is to give the credentials away. And even if that comes to be, those appraisers will still have to earn a living in a shrinking field. Not sure how that will help anyone other than education providers and bureaucrats who need to justify their jobs, but we're on our way to finding out.

 

[George Hatch]

One conclusion I do agree with is that the entire profession was remiss in not accurately foretelling the then-future rise of the "representation" argument and DEI theology. We'd be marginally better off in 2024 if TAF had previously established arbitrary race and gender quotas for board membership 30 years ago. Nothing would be different in the content of the appraisal standards or qualifications but who cares as long as the group pictures look a little more acceptable?

 

[Tiffany Gibbons]

Wow...BFF crush on that over the top piece....I'll skip reading that one...

Miller should paste that into the OCC hearing comments on YouTube, lol

 

[Zoe]

Chopra is something else. Notice he went directly at Bunton. I don't think he even looked at another witness.

 

[Zoe]

I think Chopra asked for something in writing from Bunton. I would like to read that. LOL

Bunton is retiring. Chopra did hit Bunton hard. Look for change.

 

[Zoe]

CFPB is most powerful organization the USA over lending IMHO. Chopra is no joke.

 

[Zoe]

Bunton failed test from Chopra. Look for change.

 

[djd09]

February 28, 2024
James Wylie
Associate Director of Fair Lending
Federal Housing Finance Administration (FHFA)
Enice Thomas
Deputy Comptroller for Credit Risk Policy
Office of the Comptroller of the Currency (OCC)
JeanMarie Mattingly
Deputy Director
National Credit Union Administration (NCUA)
Elizabeth Davis
Housing Program Officer
Housing and Urban Development (HUD)
Luke Brown
Associate Director, Supervisory Policy Branch
Federal Deposit Insurance Corporation (FDIC)
Art Lindo
Deputy Director for Policy
Federal Reserve Board (FRB)
The Honorable Rohit Chopra
Director
Consumer Financial Protection Bureau (CFPB)
Dear Associate Director Wylie, Associate Director Brown, Deputy Director Lindo, Deputy
Comptroller Thomas, Deputy Director Mattingly, Director Chopra, and Program Officer
Davis:
The National Association of REALTORS® (NAR) thanks you for your commitment to
improving the appraisal process for all homebuyers. Credible and fair valuations are key
to sustainable financing and REALTORS® commend the Appraisal Subcommittee for
their ongoing efforts to eliminate discrimination in the valuation process. NAR has
actively advocated for solutions that will increase diversity, reduce bias and maintain the
public trust in the appraisal profession. Among those solutions are legal clarity from HUD
regarding claims of appraisal discrimination as well as transparency and accountability
in appraiser compensation.

Clarity to Build the Right Tools

As NAR previously wrote to HUD, section one of the PAVE Action Plan notes that, “the
appraisal industry lacks clarity around its antidiscrimination obligations under current
federal laws.” 1 The Action Plan indicates that the “CFPB, DOJ, VA, and HUD will issue
guidance on the Fair Housing Act’s and ECOA’s application to the appraisal industry.” We
continue to wait for the participating agencies to issue such guidance.

Moreover, we have seen no resolution of the appraisal bias cases under investigation by
HUD. The Federal Housing Finance Agency (FHFA) has documented appraisals in which
appraisers improperly noted observations of race and ethnicity for neighborhoods they
analyzed.2 These were referred to HUD by the FHFA. We understand there are numerous
other cases of alleged appraisal bias under investigation. However, HUD has not issued its
findings in any cases to date.

Our industry relies on legal guidance from HUD and the courts to build best practices and
create training and education. Contrary to assertions made during the ASC hearing on
February 13, 2024, NAR does not believe that court filings or guidance on lending
discrimination provide an adequate corollary for guidance in real property appraisal
practice. We lack such basic information as the elements of proof for credibly claiming
that appraisal bias has occurred. Without such guidance, industry efforts are stalled. To
this end, NAR requests that HUD, the CFPB, VA and other members of PAVE complete
their reviews of alleged discrimination in valuation with due haste and provide guidance
on both documented cases of discrimination as well as cases where discrimination was
not found.

https://narfocus.com/billdatabase/clientfiles/172/3/4843.pdf

 

[Elliott]

NAR President Sears' letter is a step in the right direction and far superior than what has come out of TAF. So in addition to disclosing and breaking down appraisal fees, lets have sunshine on how Realtor CMAs operate (will they choose to ignore some comps and not others) and how will AVMs algorithms be 'modified' to meet the unknown, new PAVE standard? And how will the GSEs modify their comparable selection to avoid BIAS and Hybrid criteria. Lots of explain' to do. : )