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UAD 3.6 discussion

If there isn’t a way to clone reports that are in the same subdivision, that will be a fatal flaw in the design. They won’t have any appraisers left. hopefully the geniuses at the GSE’s understood this.
Sounds like they'll be getting EXACTLY what they wanted.


It's important to also recognize the fact that the FHFA under previous leadership, conditioned GSE executives pay scales, on their ability to use appraisers less and less every quarter, as the FHFA issued it's routine grading and oversight analysis papers. This was called the scorecard. And if one read the goals and performance metrics of what was scored, eliminating 'appraiser bias' was a central tenant of FHFA's goals. They went all in with appraiser racism immediately.

Here's the punchline; The updated UAD forms were a product of these working groups.

Although management changed, their incompetent practices remain.


The GSEs are doing this work at the direction of the
Federal Housing Finance Agency (FHFA) as part of the
Uniform Mortgage Data Program ® (UMDP ®
). This effort
is guided by input and feedback from over 100 industry
stakeholders through interviews, consultations, surveys,
and virtual bulletin boards

Hopefully a few appraisers will see the big picture as the final curtains close on the ashes of tens of thousands of appraisers soon to be vanquished GSE servicing careers.

The appraisers are racist narrative, the ensuing retooling of policy as well as radical proposals from the pave task force....

Was all bankrolled and supported by the special interest groups whom sought complete control of the housing financing markets.

And they won. They trashed decades of longstanding reliable checks and balances mechanisms in order to install a new control control automated heavy system.

The new forms are there to keep you distracted as the final work load is offloaded elsewhere. Only 98% ltv or higher, or highest risk borrowers will even receive full service appraisals. The rest is automated away or pushed through with diminished work products such as evals or hybrids.

Game over. Don't forget to turn out the lights if you're the last one to leave.

Nobody is going to do anything until the housing market unravels, and it's getting rocky right now. They have one more round of artificially low rates to right the ship for another half decade, then who in the hell knows. If they drop the lending rate and fire up the economic engine of mortgage servicing again, affordability crisis will hit epic levels, and so will the eventual tsunami of asset management activity.

FHFA FNMA compensation plan rules, tied to using appraisers less.JPG

mortgage backed securities graph 2.JPG
mortgage backed security.jpgmortgage backed securities meme.jpg
 
Nobody at the GSE is commenting on this aspect. The silence is deafening.

The software companies are tight-lipped about what can and cannot be done, but so far, Alamode says there is no way to merge a template or old report ( their version of cloning ), and it might be available later , and that they are working on it .
The GSEs are not developing the appraisal software, so not much if anything they can say about how in will function. Any abilities within the software will be up to the software developers. The question I have concerns the record keeping rule of USPAP. If everything is cloud based. How much control will I have to guarantee the integrity of and ability to access the files on demand. Or am I going to be at the mercy of the server gods.
 
I didn't see predatory lending in that list. By definition, a bad loan is one in which payments aren't being made. The only time that happens is when: (1) the borrower never intended to repay the loan (fraud), (2) the borrower intended to pay but found he/she couldn't afford it (predatory lending), or (3) the borrower intended to pay but something happened (tragic circumstances).
A bad loan is when the borrower stops paying ( or is very late on payments )

But what saves the public and investors from taking big losses when a loan goes bad is the collateral ( Real property) that the bank has rights to foreclose on and sell. If the property was not overvalued at the time of the loan, there should be some equity there and salvageable collateral to sell.

Of course, a property can be trashed or have a market decline since the time of the loan as well, but it is the collateral at the time of the loan made and down the road that anchors the system and allows the favorable interest rates and terms of the taxpayer-backed loan market, whether the valuation was done by an appraisal or AVM or other.
 
The GSE really pick and choose what they claim to have say over and what they don’t. But if you’re a member of the breakfast club, rest assured, you’ll be taken care of.
 
If there isn’t a way to clone reports that are in the same subdivision, that will be a fatal flaw in the design. They won’t have any appraisers left. hopefully the geniuses at the GSE’s understood this.

Nobody at the GSE is commenting on this aspect. The silence is deafening.
I don't think the GSE's will have anything to do with whether or not there will be an ability to clone reports or use templates. That will be up to the appraisal software companies to create that functionality within their software and my guess is that they will all do so evwntually because it is quite likely that at least one of them have either already figured out how to to do that or will soon figure it out and once one company figures it out, they will all have to do it unless they want to lose market share to the company that offers it. Even if the GSE's did not want the software companies to offer that functionality, there is nothing they could do to stop it....certainly the new appraisal software will offer the ability to save reports and the the data contained within them so that if any revisions are requested, the appraiser can make those revisions without havving to start completely over by creating an entirely new report and once you save the data, you can the feed the data back into the software through an interface to create a new (cloned) report.
 
A bad loan is when the borrower stops paying ( or is very late on payments )
I thought that's what I said?

But what saves the public and investors from taking big losses when a loan goes bad is the collateral ( Real property) that the bank has rights to foreclose on and sell. If the property was not overvalued at the time of the loan, there should be some equity there and salvageable collateral to sell.
No, what saves the public and investors is when those lending money - especially money that's not theirs - make sound lending decisions. And those sound lending decisions are (historically) based on appraisals.
 
The GSEs are not developing the appraisal software, so not much if anything they can say about how in will function. Any abilities within the software will be up to the software developers. The question I have concerns the record keeping rule of USPAP. If everything is cloud based. How much control will I have to guarantee the integrity of and ability to access the files on demand. Or am I going to be at the mercy of the server gods.
In the seven years of development, The GSE's must have spoken wiht the software companies, esp since they are owned by the corporate players who own MLS , data etc ( Core Logic for one ) Surely the software companies must have communicated to the GSE's that a cloud based "dymanic form" would not be compatible with the current way appraisers work ( and save time ) with the current forms which can use templaces, merging or drop in saved comments.

It's not too late - the GSEs can scrap the dynamic form and simply update the current forms to include the data fields and photo sections they want .

But out of pride and to safe face lets assume they won't - which will expose the appraiesrs to the blame of taking too long on each report, not being able adapt to new tech etc.
 
I thought that's what I said?


No, what saves the public and investors is when those lending money - especially money that's not theirs - make sound lending decisions. And those sound lending decisions are (historically) based on appraisals.
Sounder lending decsions help, but no system is fool proof and people can lose jobs, get sick go crazy and markets can turn as well, disasters strike etc.

If the collateral is still standing it anchors the loan. Otherwise it would be like siganture loans or unsecured credit card loans at triple interest rates or private $ mortrgages with 5 year balloon payment due.
 
Sounder lending decsions help, but no system is fool proof and people can lose jobs, get sick go crazy and markets can turn as well, disasters strike etc.

If the collateral is still standing it anchors the loan. Otherwise it would be like siganture loans or unsecured credit card loans at triple interest rates or private $ mortrgages with 5 year balloon payment due.
Think about it this way: The appraisal doesn't make the loan 'better'; you could have a stellar appraisal and still make a poor lending decision. The appraisal is information that the lender uses to assist them in making sound lending decision(s). It's the lending practice that determines the quality of the loan - not the appraisal.
 
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