Treasury Department Recommendations

[Non Sequitur]

If the benchmark is the contract date then what difference does the "front end" make in the turn times for both? Both would be impacted by the same "front end" issues.

There's no way to measure the time from contract date, to presentation to the lender, to appraisal order date. The VaCAP survey is drawing a conclusion from contract dates, it's myopic at best. If anyone wants to defend appraisers regarding turn times, then measure order date to submission. If VaCAP wants to argue that AMC's add to that time (I doubt anyone who has that data would make it available) a reliable survey illustrating direct order turn times may be the way to go.

 

[Joe Flacco]

There's no way to measure the time from contract date, to presentation to the lender, to appraisal order date. The VaCAP survey is drawing a conclusion from contract dates, it's myopic at best. If anyone wants to defend appraisers regarding turn times, then measure order date to submission. If VaCAP wants to argue that AMC's add to that time (I doubt anyone who has that data would make it available) a reliable survey illustrating direct order turn times may be the way to go.

I don't know much about the survey but if you have 1000 AMC appraisals and 1000 direct lender appraisals, then why would the average "front end" time be much different? You are basically arguing the AMC appraisals have longer "front end" time. It is a reasonable assumption that they both have similar "front end" times.

 

[Dale Floyd]

There are several things that could be improved that would speed up the process. A good start would be to order the appraisal much earlier in the application phase rather than waiting until all the verifications and/or certifications checks out. That’s one of the reasons we see purchase contracts that are dated 2-3 weeks before we get the request. AMC’s should deliver reports immediately to the lenders rather than stalling because of nonsense stipulations that have nothing to do with compliance or USPAP. Stop the idiocy of forcing the appraisal report to be revised to match other non-appraisal documents in the mortgage file. (The appraisal is not the title opinion, or the tax assessment..)

And I take issue with those who keep saying the process of appraising hasn’t changed. I remember the days of clipboards, courthouse visits to find sales, 35mm photos, wheel or tape measurements, rubbed arrows on a xerox map, dot matrix printers with the Forms and Worms triplicate appraisal perforated forms, DOS, etc. I think we appraisers have progressed more than many professions. But there are some things that might be best to leave alone, like the property inspection. An experienced appraiser should be the most sane and least biased voice in the entire process. The more detached the appraiser is from the property, the less reliable the analysis is going to be.

I’m sure my long gone granny’s method of making those cat head biscuits and strawberry freezer jam is considered outdated and too slow by many today, but her great grandchildren still do it just like she did. Never heard anybody suggest her methods of old are too outdated either once they have the opportunity to test the results.

 

[Evincere]

There are plenty of accounts here, recent and over the years, of the worst AMCs shopping appraisals for weeks for fees. Direct lenders don't do that, well, make that--at least not for long. Bankers' hours are not what they used to be. My point is that there are a lot of things going on and a lot of parties involved, none of whom want any blame. Everyone seems stressed, at least at this altitude (sea level). But yes, delays will be laid at our door.

Righto on the bargain basement shopping many AMC do. Something a special person who gets contracts with in hours completely failed to mention.

 

[Evincere]

There's no way to measure the time from contract date, to presentation to the lender, to appraisal order date. The VaCAP survey is drawing a conclusion from contract dates, it's myopic at best. If anyone wants to defend appraisers regarding turn times, then measure order date to submission. If VaCAP wants to argue that AMC's add to that time (I doubt anyone who has that data would make it available) a reliable survey illustrating direct order turn times may be the way to go.

Fine, since as you say there is no way to measure the time let the propaganda Articles pushing PIWs and hybrids because one of the benefits to the consumer is that they Expedite the closing process. Cease and desist.

Because obviously those making such allegations are also basing their claims on false data and misrepresentation.

PS: Crafty Misrepresentation that implies Appraiser inspection delays and shortages impede profits and that the general public will be beneficiaries of fast track closings

 

[J Grant]

Fine, since as you say there is no way to measure the time let the propaganda Articles pushing PIWs and hybrids because one of the benefits to the consumer is that they Expedite the closing process.

Because obviously those making such allegations are also basing their claims on false data and misrepresentation

Certainly a PIW waiver expedites closing, only a certain % of properties/loans qualify but they are expanding the limits to include more. Hybrids /bifurcated to replace traditional appraisals might save a day or two. They've sold saving day or two off closing as justification to overhaul appraising.

The justification faster benefits consumers is BS, what benefits consumers is not being rushed and railroaded into making important buying/ borrowing decisions. But rushed , locked in borrowers is what they want, close at lightening speed before borrower has a chance to change lenders or change mind. Quicken Rocket Mortgage leads the way. Instead of Fannie saying maybe the Quicken model creates more risk and pressure for consumers so let's keep a brake on for prudence Fannie jumped in to remodel everything to match Quicken speed model. Will see long term how it plays out

If appraisers are needed at some point to review or go back out and re appraise some of the fast hybrid work or waived properties. is unknown. As the saying goes, fasten your seat belts it's gonna be a bumpy ride!....

 

[ucbruin]

@J Grant

You make some good points.....

Yet....
Based on current DOM.....

I don't understand how anyone other than the buyers are to blame for rushing the system....

 

[J Grant]

@J Grant

You make some good points.....

Yet....
Based on current DOM.....

I don't understand how anyone other than the buyers are to blame for rushing the system....

?? What does that mean? DOM are days a property is listed and has nothing to do with speeding up a closing . The speeding up lenders want is from time a borrower applies for a loan to day it closes, whether a refinance or purchase. It's absurd to think it will make a purchase close faster because the closing date for a purchase is set in the sale contract. Which leaves mainly refinances, so Fannie and congress believe getting funds to lender faster for refinance closings is worth overhauling the system.

 

[ucbruin]

To me, the risks to the overall housing market seems to be created by the sellers/buyers....

 

[J Grant]

To me, the risks to the overall housing market seems to be created by the sellers/buyers....

Agree, however US taxpayer underwrites those risks with mortgages insured by Fannie etc.

The actions of buyers/sellers when lenders enable over leveraging and green light inflated prices spreads to refinance for owners . When prices jump, owners are tempted to use house as an ATM because they have more equity and banks push it too- offering HELOCs. cash out refinance etc. THAT is how aprox 40% of American homeowners ended upside down in their mortgages after the crash...and even without a crash, over leveraging properties by homeowners means their equity shrinks and they are strapped with higher payments and debt.

Fannie, Freddie and FHA are abandoning their role as the "brake" on risk by overhauling the valuation ( and lending process ) to accelerate things. I can't speak about cloud docs or digital mortgages what that will mean as far as increased risk, my opinion that the rush to accelerate valuations and eliminate appraisals from a segment and use hybrids to replace others increases risk, but like the housing market boom and crash nobody listens to appraisers so...