Virgina REAB and Portal Petition

[TJSum]

Actually the entire quote from my post was...

"So if I understand correctly... An attempt by AI to assemble a national database is good, but if any other entity were to try to assemble a national vault system this it is bad and those in charge could not be trusted?"

That is why I distrust conversion programs that can move the words around...

Feasible? How long would it take and how expensive would it be to have the vault in PDF. Any client can design their system to meet that. DW you even stated they already have the means to convert PDF's into AI Ready.

 

[DWiley]

Any client can design their system to meet that.

Do you think clients will be any more willing to convert their current system than appraisers are? No. Clients who use RIMS, Encompass, AppraisalPort, Realty Services, et al, will have no desire to re-engineer their IT systems to integrate with something else.

Who would pay for the system? Who would be responsible for the lawsuits initiated by current web portals that would be put out of business? These are not small issues.

 

[George Hatch]

I'm still at the same place I was when all this started. If these web portals are actually changing the content of these reports or they're applying signatures to supplemental recaps the appraiser never saw then that has to stop. OTOH, if they're taking data that's formatted for one appraisalware program and merely transferring it into the same report form (as in. Fannie's 1004 or 2055) but in another appraisalware suite or even the clients proprietary software suite then I don't see the problem with that. As long as I can modify my format on my end so that what I'm printing out is what my client receives then I'm good. I just don't want anybody to be editing or deleting my analyses, opinions or conclusions. Especially not my clients.

If anything, I expect my appraisalware vendor to provide me with the same forms/formats as used by these portals so that I don't have to take that extra step of reviewing the portal's version before I send it. Of course, the portal companies could do the same.

The datamining thing is a problem in my eyes to the extent that data is being used to populate AVMs with which appraisers are directly competing. Unfortunately, I'm afraid that the datamining issue will eventually come down to a take-it-or-leave-it ultimatum wherein an appraiser either agrees to allow these companies to take their data or they don't accept the assignment.

Right now these lenders and the portal companies have extra leverage because of the supply/demand situation with appraisal services. They didn't create it (appraisers did), but they sure won't hesitate to exploit it.

I'm hoping the VA board exercises a little restraint and limits the scope of their actions to preventing these companies from changing content. Otherwise I fear the unintended consequences.

I sincerely doubt we will be able to force our clients into accepting only pdf files. That genie has left the bottle.

 

[DWiley]

What the Appraiser sees/prints via any AppraisalPort viewer is not what is actually sent. The report is reduced to nothing but data, no form is actually sent in the file.

That is correct. That is the way most forms software works (ACI, Appraise-It, etc.). There is no need to waste file space by including the form in the file.

There is a code indicating the form that was used as a template for the form. If you open up one of your appraisal files in Word you can probably see a code near the beginning of the file indicating the form.

When I open one of my report files in Word there is an imbedded tag that says UA5. This tells my forms software to show the report on the new Fannie Mae form. AIReady works the same way.

 

[TJSum]

Do you think clients will be any more willing to convert their current system than appraisers are? No. Clients who use RIMS, Encompass, AppraisalPort, Realty Services, et al, will have no desire to re-engineer their IT systems to integrate with something else.

Who would pay for the system? Who would be responsible for the lawsuits initiated by current web portals that would be put out of business? These are not small issues.

If appraisers are "free" to sign all of the Certifications on the current forms, and are just as "free" to choose whether to use these conversion programs or not, why shouldn't we share this freedom and allow the lenders the same freedom to "choose" a mandated Standardized True Copy if they wish to be involved with GSE loans.

Debating what actually is a true copy sounds too much like debating what the definition of "is" is. IMHO it is no different than mandating a standard currency or language for the country so that commerce can proceed in an orderly fashion. It is just common sense and sound business practice for the Public Trust.

 

[DWiley]

why shouldn't we share this freedom and allow the lenders the same freedom to "choose" a mandated Standardized True Copy if they wish to be involved with GSE loans.

I have no issue with that, but it is the GSE's that would have to be convinced.

 

[George Hatch]

I have alamode. The native report file formats for that program have .BZ1 and .ZAP file extensions. When I start a new report in alamode, it saves the report in that file format, both before and after I apply my signature.

In addition to printing the report out as a hardcopy or as a pdf, I could just send the .zap file to another alamode user, who could then print my report from their computer using their copy of the alamode software.

Whether I send that file to them as a hardcopy, pdf file or alamode (.zap) file, my report remains the same, signed and without alteration. Come to think of it, you could make the argument that the alamode .zap file is the real thing and the pdf and paper versions are the copies.

Can alamode crack that file and remove my signature and anything else in it? I don't know for sure but it wouldn't surprise me either way. Alamode runs its own Vault program, which many of its subscribers use. For all I know, alamode might be able to load my 1004 report into a 2055 form or some other form; I know I can do it on my end. I think it would surprise me more if they couldn't do that conversion than if they could.

If I was using alamode's vault, should I be concerned about their capabilities? Maybe. I'm not worried so far because I've seen no indication that they're doing anything like that with those files.

Now I can't say that I trust FNC as much as I trust alamode, but that's probably a personal bias on my part. If I knew for sure FNC was changing values and stuff I'd be hot, but so far we only have a few allegations and I have yet to see a smoking gun.

I'm open to more information at this point, but I'm just not prepared to get hot about file formats as a single issue.

 

[woodyva]

FNC got a viewer, wow! It seems many think the meeting forthcoming is just for FNC. It is not, it for conversions period.

I have no idea what FNC does with the reports. My issues with it have been to stop forcing the appraisers to only include certain things in the reports. We need the ability to determine what and how we analyze wgich data we feel is relevant. Danny Wiley has been as open about disagreeing with the format limitations as I continue to be.

Rest assured the committee meeting is for more than FNC. I gain nothing from whether they stay in business or not. I care that we are able to determine how we do our work and how that we are able to present it so that the public trust is protected.

I agree with Mr. Dodd in that USPAP is set up to protect the lenders. It is not there for us, or for the general public's protection. It is a failed concept in that it should hold the general public's overall health in these matters to be paramount. Lender guidelines can and should be met with the scope of work from the lender on the order form.

My questions at this point is: should a scope of work requirement/request from the lender impede or cause the appraiser to violate USPAP, is it not the appraiser's responsibilty to not comply with the request?


Sorry I have not replied in a while, I was in the Bahamas trying to decompress from a busy year. I did get a chance to catch up on the posts in the mean time of returning to the states.

I have to say Ken Brown, with every post you confirm what we all have known: you are one on point guy with nothing but integrity flowing forth from your every word, thought and action. :new_smile-l:

 

[Workbox]

Woodyva, there are so many banker folks that now use a portal system. Transunion now require a similar system to download the PDF. And Capital One also has their RIMScentral. So we knew from the beginning it was not just about one particular portal system. But the the rush to produce viewer is a sure indicator of the inquiries.

But when I was speaking to an insider to one of these portals, they told me that they have halted all access to any kind of manipulation to the reports by personel. Usually the issue appraisals went to the higher up. So yes, some have indicated on the ease of how some of these systems have allowed them to manipulate appraisal data.

 

[George W Dodd]

That is correct. That is the way most forms software works (ACI, Appraise-It, etc.). There is no need to waste file space by including the form in the file.

There is a code indicating the form that was used as a template for the form. If you open up one of your appraisal files in Word you can probably see a code near the beginning of the file indicating the form.

When I open one of my report files in Word there is an embedded tag that says UA5. This tells my forms software to show the report on the new Fannie Mae form. AIReady works the same way.

Mr. Wiley proves the point perfectly. The moment the Appraiser sends the report AIReady, they have violated the USPAP, Supplemental Standards, and likely their State's Rules & Regs. Here is what Fannie states, please try to reconcile this with sending a "data file":

XI, 203: Appraisal and Property Inspection Report Forms (11/01/05)An appraiser may use computer software programs that are designed to reproduce our appraisal report forms —including programs that have “expandability” features that allow increases in areas of the forms that call for the insertion of narrative comments. However, the sequence of the information —as well as all of the specific information (including the instructions, entries, directions, etc.)—must be exactly as it appears on the hard-copy of the form(s).

A lender may accept an appraisal report that is transmitted electronically using facsimile machines, Internet connections, wireless transmissions, or any other types of transmissions
that use public or private telephone lines —as long as the appraisal report adequately identifies the appraiser and includes a reproduced signature of the appraiser whose name appears on the report, and the lender represents and warrants to us that the appraisal report was created by the appraiser identified on the appraisal report and that the appraisal report is the complete and unaltered report submitted by the identified appraiser.

CLEARLY, THE APPRAISER MUST SUBMIT A REPORT, NOT A DATA FILE. "THE APPRAISAL REPORT WAS CREATED BY THE APPRAISER" .... "COMPLETE AND UNALTERED REPORT"

Note the specific use of the term REPORT, it does not say "data file". The entire AIReady joke is on the Appraiser and their willingness to do anything to not upset the client. Please read the USPAP:

Scope of Work Rule: (410-411) An Appraiser MUST NOT allow assignment conditions to limit the scope of work to such a degree that the assignments results are not creditable in the context of the intended use.​

(419-420) An Appraiser must not allow the intended use of an assignment OR A CLIENT'S OBJECTIVES TO CAUSE THE ASSIGNMENT RESULTS TO BE BIASED.​

Standards Rule 2: (612-613) ...an Appraiser must communicate each analysis, opinion, and conclusion in a manner that is not misleading.​

​