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The Appraiser Shortage Myth Part 43

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Neither I nor my company take any part of the appraisers' fees. Appraisers set their fees and we pay those fees. When I deal directly with an appraiser and ask that appraiser to tell me what is his/her fee, and then I pay that, how am I "taking" the Appraiser's fee. I am not taking it - I am paying it. :)
I will agree, from first hand knowledge (FTR - people I know working there; I don't work with your company), your company does what you say quoted above.

As far as the "48 hr TAT" after inspection (maybe you can save me a phone call or two) does your company have this policy?

If not a company (Servicelink) policy, do some of your lenders require this? (48 hr TAT after inspection)
 
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Well...uhm...no. LOL. Have you? Do tell. Do they talk about appraisals and impose sanctions or just talk about them and then impose a beer at the bar?
Sure- there isn't anything secret about this.

The current push by the regulators is to focus on the review standards that institutions must meet. Little known is a requirement that the institutions set up an auditing process to qualify the reviewers they engage and to review the reviewers and their product. In other words, institutions have to document that the appraisers they hire as reviewers are competent in the property type and (i in the case where the reviewers provide their own, independent value) are competent in the markets where they work.
In order to do this, the reviewer's qualifications will be reviewed as well as the review reports and the original report under review.

I would think that will make many happy: reviewers who work for regulated institutions will have to be qualified, competent, and the quality of their product will be regularly evaluated.
While it isn't practical for a federal regulator to audit individual appraisals on a large scale, it is practical for a federal regulator to audit the review process that is in place. By auditing the review process, the institution and reviewers will be held accountable for the quality of their work. Their "quality" is directly linked to the original appraisal they have reviewed. In order evaluate the reviewer, both the review and original report under review will have to be evaluated.

Reviewers who are not competent or qualified will run into issues when they are audited.
Reviewers who are inappropriately applying the review standards to the work under review will have issues when they are audited.
Reviewers who sign-off on below-standard appraisals will have issues when they are audited.

The principal of applying the most effective focus on the point where it will have the maximum impact is at work.

It is no doubt obvious to you what the outcome of this increased scrutiny will be. If quality is lacking on the original appraisal level and that lack of quality (as measured by non-credible results and failure to meet the reporting standards) and it is not being addressed on the review level, by means of the review audit, that will change.

This force is already at work. Don't expect an overnight change but expect a change. It is already happening.

One negative consequence of the above is that some institutions/reviewers may over-react. That overreaction will result in a higher level of scrutiny at the original appraisal level. More scrutiny = more requests for additional data and comments. I don't anticipate that being the majority reaction, but it doesn't need to be a majority reaction to have a disruptive impact on the field appraiser. In the end, things will balance out.

Like any other enforcement action, it only works if it is (a) actually applied; (b) applied consistently; (c) applied evenly and to everyone, and ; (d) the expectation is that the enforcement will be sustained and not a flash-in-the-pan.

Anyone who avails themselves to the opportunity to participate at events where these issues are discussed by the parties (regulators) who enforce them can hear about it first hand. Anyone who avails themselves to the opportunity to participate at events where the lenders are reacting to these changes can hear how they are implementing the audit process.
Of course, I'm giving you my interpretation of what the presenters have said. No doubt someone else may have a different interpretation.

Ergo, my optimism that change is in the works. Like anything else, if it happens as I've laid it out, some may be happy; others, maybe not. :cool:.
 
I will agree, from first hand knowledge (FTR - people I know working there; I don't work with your company), your company does what you say quoted above.

As far as the "48 hr TAT" after inspection (maybe you can save me a phone call or two) does your company have this policy?

If not a company (Servilink) policy, do some of your lenders require this? (48 hr TAT after inspection)
As I have said before, that is a goal, not a requirement. :)
 
DW Neither I nor my company take any part of the appraisers' fees. Appraisers set their fees and we pay those fees. When I deal directly with an appraiser and ask that appraiser to tell me what is his/her fee, and then I pay that, how am I "taking" the Appraiser's fee. I am not taking it - I am paying it. :)
Sorry you never read the part in the C&R rules about how the market should be the driving force. As an appraiser I would hope you would understand that concept.


I see in the final rule C and R reference VA fees, govt surveys and NON AMC's fees to be used (as the "market driving force")...Why are AMC fees so much lower than private or direct lender with no AMC, or VA work in so many areas?

The only fees you pay to appraisers are to those appraiser who charge the lowest. I am on your panel in FL, signed upp 2 years ago have gotten zero work at "my fee" ( which is a very reasonable fee but not bottom tier ) My friend in CA on your panel experienced the same, the only time she got orders was when "her " fee was very low, whenever she quoted higher she got nothing. She did not renew her credentials next sign up I suppose I wont; either .

You dont' pay appraisers "their " fees, unless "their" fees are the lowest of the tier. So tell me, how do appraisers set their own fees, when the fees the appraiser sets results in zero work unless the appraiser drops the substantially?

You retain part of the fee the borrower paid for the appraisal as our profit, therefore less goes to the appraiser from the amount. IF instead you charged your lender customer a rate for your service separate and apart it would end the cat and mouse game playing
 
DW Neither I nor my company take any part of the appraisers' fees. Appraisers set their fees and we pay those fees. When I deal directly with an appraiser and ask that appraiser to tell me what is his/her fee, and then I pay that, how am I "taking" the Appraiser's fee. I am not taking it - I am paying it. :)
Sorry you never read the part in the C&R rules about how the market should be the driving force. As an appraiser I would hope you would understand that concept.


I see in the final rule C and R reference VA fees, govt surveys and NON AMC's fees to be used (as the "market driving force")...Why are AMC fees so much lower than private or direct lender with no AMC, or VA work in so many areas?

The only fees you pay to appraisers are to those appraiser who charge the lowest. I am on your panel in FL, signed upp 2 years ago have gotten zero work at "my fee" ( which is a very reasonable fee but not bottom tier ) My friend in CA on your panel experienced the same, the only time she got orders was when "her " fee was very low, whenever she quoted higher she got nothing. She did not renew her credentials next sign up I suppose I wont; either .

You dont' pay appraisers "their " fees, unless "their" fees are the lowest of the tier. So tell me, how do appraisers set their own fees, when the fees the appraiser sets results in zero work unless the appraiser drops the substantially?

You retain part of the fee the borrower paid for the appraisal as our profit, therefore less goes to the appraiser from the amount. IF instead you charged your lender customer a rate for your service separate and apart it would end the cat and mouse game playing
See Denis' prior post. It addresses all your concerns.
 
I don't need Denis posts, I see results in real life, my own and other appraisers order flow and income and how low we need to bid to get work from your AMC/similar.

Why dont' you just charge the lender clients a separate rate per order apart from borrower paid charge? Your company could do that tomorrow, could it not?
 
Sure- there isn't anything secret about this.

The current push by the regulators is to focus on the review standards that institutions must meet. Little known is a requirement that the institutions set up an auditing process to qualify the reviewers they engage and to review the reviewers and their product. In other words, institutions have to document that the appraisers they hire as reviewers are competent in the property type and (i in the case where the reviewers provide their own, independent value) are competent in the markets where they work.
In order to do this, the reviewer's qualifications will be reviewed as well as the review reports and the original report under review.

I would think that will make many happy: reviewers who work for regulated institutions will have to be qualified, competent, and the quality of their product will be regularly evaluated.
While it isn't practical for a federal regulator to audit individual appraisals on a large scale, it is practical for a federal regulator to audit the review process that is in place. By auditing the review process, the institution and reviewers will be held accountable for the quality of their work. Their "quality" is directly linked to the original appraisal they have reviewed. In order evaluate the reviewer, both the review and original report under review will have to be evaluated.

Reviewers who are not competent or qualified will run into issues when they are audited.
Reviewers who are inappropriately applying the review standards to the work under review will have issues when they are audited.
Reviewers who sign-off on below-standard appraisals will have issues when they are audited.

The principal of applying the most effective focus on the point where it will have the maximum impact is at work.

It is no doubt obvious to you what the outcome of this increased scrutiny will be. If quality is lacking on the original appraisal level and that lack of quality (as measured by non-credible results and failure to meet the reporting standards) and it is not being addressed on the review level, by means of the review audit, that will change.

This force is already at work. Don't expect an overnight change but expect a change. It is already happening.

One negative consequence of the above is that some institutions/reviewers may over-react. That overreaction will result in a higher level of scrutiny at the original appraisal level. More scrutiny = more requests for additional data and comments. I don't anticipate that being the majority reaction, but it doesn't need to be a majority reaction to have a disruptive impact on the field appraiser. In the end, things will balance out.

Like any other enforcement action, it only works if it is (a) actually applied; (b) applied consistently; (c) applied evenly and to everyone, and ; (d) the expectation is that the enforcement will be sustained and not a flash-in-the-pan.

Anyone who avails themselves to the opportunity to participate at events where these issues are discussed by the parties (regulators) who enforce them can hear about it first hand. Anyone who avails themselves to the opportunity to participate at events where the lenders are reacting to these changes can hear how they are implementing the audit process.
Of course, I'm giving you my interpretation of what the presenters have said. No doubt someone else may have a different interpretation.

Ergo, my optimism that change is in the works. Like anything else, if it happens as I've laid it out, some may be happy; others, maybe not. :cool:.

Fair enough. I officially retract my comment that you are naïve, and (maybe) charge myself. I am still slow to think regulators will dig in deep, but who knows, appraisers are the preferred punching bags of the industry. I do not hold the same optimism you do however, as I wonder how increased regulations over an imperfect appraisal process/forms is going to be good. What I mean is that we will have people offering an opinion about an appraisal that was performed on an imperfect and unrealistic GSE form, that in some cases sets an impossible expectation on the appraiser. I am scared of sitting in front of a state board for the very same reason - not because I doubt my ability, but because I doubt the ability of others. I am also scared of people in a position of power over me who get a kick out of throwing their weight around. Again, if the forms and methods were appropriate and reasonable, I would not worry about this, but they aren't, so I am.
 
You dont' pay appraisers "their " fees, unless "their" fees are the lowest of the tier. So tell me, how do appraisers set their own fees, when the fees the appraiser sets results in zero work unless the appraiser drops the substantially?
JG, I'm not defending Servicelink by any stretch of the imagination. I am not a fan of the company by any means. But as I've said before, I'll call a spade a spade.

I lost a nice chunk of business by them buying out ULS (about $20k/yr) but I do know people there. That is why I will say that they do pay the appraiser's fee. It's a technicality, but it's true. If the appraiser has his/her fee set at $250 or $350 or whatever for an assignment, they do pay that. SLink doesn't come up with that fee, the appraiser does. They pay the "appraiser's fee" for the assignment. So it is the appraiser's fee!

If appraiser's feel they are only worth $250 - $285 in my county ($300 seems to be the upper end for the Link here - Pinellas) then so be it. Again, I've been that $250 guy before; it sucks, but ... so do many other things in life. Fees, along with a few other things, are the reasons I won't do business with Servicelink. The fee thing isn't because I don't think they'd pay my published fee for an assignment, it's because ... well, it's Servicelink and I don't want to work for them
 
If a borrower is paying $700 for an appraisal and the appraiser is getting $200 (hypothetical), the difference is going somewhere.

That's where it gets sticky because appraisal requires a license in many states.
 
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