Virgina REAB and Portal Petition

[George Hatch]

That only means he probably gutted his explanations.

But let's assume he didn't change anything. So what?

You don't know who his original intended users were or what their requirements are, nor do you have the right to make any assumptions.

MOST appraisers don't provide line-by-line explanations for the adjustments they use, nor are they required to in SR2-2.b nor are they even required to by the verbiage on those forms. If his client and intended users were a local community lender who was already very familiar with the market conditions and the impact of financing then no additional explanation of any type would be necessary for their intended use.

The point is that you don't know the circumstances of his original assignment, but are instead apparently making blind and unsupported allegations about competency about an individual whom you know to be qualified to perform that type of assignment. All because he holds an opinion that's obviously contrary to your interests with this petition, NOT because you care one way or another about his original intended users or a client of your own.

As far as I can tell you're projecting a personal preference as a minimum USPAP standard, which if you were acting as a reviewer would be an ethical violation. From my perspective I would not wish to be standing on the ice you've chosen to jump up and down over.

 

[woodyva]

I dispute the notion that these formats signficantly infringe on an appraiser's ability to adequately communicate their analysis, opinions and conclusion in a manner that is meaningful and not misleading.

I also dispute the notion that appraisers rights automatically take precedence over the needs of the intended users. We provide a service, for which we are paid, even if poorly. We can't very well take their money while at the same time telling them that our desire for convenience outweighs their desire to get their reports in a format that they can use in multiple ways.

We especially can't be making the argument that it's primarily about report security and integrity given the known vulnerabilities of these pdfs.

George:
There is no grounds for an arguement about PDF security. These other formats do not offer security either. The only way to prevent anything is to hand deliver your report and stand beside it until the deal closes.

The security that these portals give begin and end with the delivery. Once the other side opens the report, you can't be 100% sure. I doubt there are many, if any, instances of an email going to an unintended party and that wayward receiver changing the report. Possible yes, probable no.

Common sense for most lenders is to look at what is easiest to work with, and that allows for meeting the needs of both sides. In honesty, receiving a PDF through a portal gives as much security as delivering an ENV through a portal. There is no doubt or secret that there are plenty of programs that inexpensively comb through and lift the data from a PDF and then convert that data so it can be run through a QC or rule set variance program.

None of this is rocket science. The portal companies would have you believe that the need certain formats, but it has zero to do with ease of use for us, or for the lender. They need it in a certain format so they are able warehouse the data. I will repeat again that I do not care that they are doing this. That is a separate issue to this one.

I think that all of us are led down the path of deceit for the sake of another's intentions. I mean that to include the lenders and the appraisers. I do not think the lenders care what format the get, as long as it meets the needs. They are sold something based on it's cost and what it can do. That is why no lenders are concerned enough to attend the meetings. I doubt they want to be cast in the shadows of doing anything to limit what we do, at least as far as the public can see. They do not worry as it is not the lende rthat i slimiting the format, it's their 3rd party.

 

[George Hatch]

I completely agree with everything you posted above.

I would also note that all of your observations are related to the business of appraising rather than issue of report integrity. If there really is a case for the latter then that's something the VA board has a right and maybe even an obligation to get involved with. If it's really about the former then the VA board should stay out of it.

Business agreements are subject to negotiation. Report integrity is not, nor is an appraiser's obligation to act competently when providing (including communicating) professional appraisal services.

IMO. Reasonable people will, no doubt, disagree.

 

[woodyva]

I think this is a pretty elegant compromise. If the issue really is report security and integrity then the only downside is the additional demands on bandwidth and storage capacity - I think that's a price everyone could live with.

Would any of the pro-petitioners care to comment on this suggestion?

I have said similar things in the past. Folks keep alluding to some larger mission, but this all I am asking for.

 

[woodyva]

I completely agree with everything you posted above.

I would also note that all of your observations are related to the business of appraising rather than issue of report integrity. If there really is a case for the latter then that's something the VA board has a right and maybe even an obligation to get involved with. If it's really about the former then the VA board should stay out of it.

Business agreements are subject to negotiation. Report integrity is not, nor is an appraiser's obligation to act competently when providing (including communicating) professional appraisal services.

IMO. Reasonable people will, no doubt, disagree.

Bravo George!

I will leave it as this: you are business negotiations are not really REAB concerns. I do see appraisers needing to compromise their reporting to adhere to assignment requirements with portals. I think a very basic form filler with minimal extras will work fine. Danny's example did show that. FNMA does allow us to add onto the SOW as we feel the need to. I am thinking that we should be able to develop, and report without the limitations. Some of these portalsdo exteremly limit you. AP is not the worse, but they get focused on as they are the big boys, and let's face it, many people think this fight is over the lawsuit with FNC. I can attribute, at least for myself, that it is not.

 

[TJSum]

To me, this is really pretty simple. Its not that big of a deal. The delivery of the appraisal report shoudl contain two files. One is a pdf document that we create. The other is a data packet, in a common format that can be used by the client's to populate their computer systems. It can not be that hard, can it? The most difficult part would be getting the industry (lenders and software providers) to agree on the common language/format in which to transmit the data packet.

Please explain to us tech challenged appraisers what this means.

Would there then be two separate versions of the report the appraiser would then be held responsible for, the "true copy" and then some "data packet"?

Is so, how does this address the appraiser's liability issues brought on with the conversion programs, if it makes us now responsible for two separate versions of the same report..... no thanks.

Let the appraiser produce one "true copy" of each report, and let those who are going to benefit from the "conversions" or other "data packets" do it themselves and take on the liabilities involved, seeing how they are the ones reaping the benefits.

 

[woodyva]

Please explain to us tech challenged appraisers what this means.

Would there then be two separate versions of the report the appraiser would then be held responsible for, the "true copy" and then some "data packet"?

Is so, how does this address the appraiser's liability issues brought on with the conversion programs, if it makes us now responsible for two separate versions of the same report..... no thanks.

Let the appraiser produce one "true copy" of each report, and let those who are going to benefit from the "conversions" or other "data packets" do it themselves and take on the liabilities involved, seeing how they are the ones reaping the benefits.

TJ:
i think perhaps a statement of limited liability included in both reports in a couple of different spots would suffice to preclude you from being hurt.

 

[Pamela Crowley (Florida)]

Please explain to us tech challenged appraisers what this means.

Would there then be two separate versions of the report the appraiser would then be held responsible for, the "true copy" and then some "data packet"?

Is so, how does this address the appraiser's liability issues brought on with the conversion programs, if it makes us now responsible for two separate versions of the same report..... no thanks.

Let the appraiser produce one "true copy" of each report, and let those who are going to benefit from the "conversions" or other "data packets" do it themselves and take on the liabilities involved, seeing how they are the ones reaping the benefits.

That is exactly what needs to be done.

The one 'true copy', not a 'converted' version but the one the appraiser originated with ALL pages and comments where the appraiser put them, is the ONLY version that should be delivered to the named lender/client.

 

[George Hatch]

A "Print" button on the .ENV viewer and one or two more supported addenda satisfies all reasonable expectations of WYSIWYG. The security/integrity issue will remain strictly within the eye of the beholder.


After that it will (again) come down to a business decision for appraisers. I think we all know how that decision will turn out.

 

[woodyva]

A "Print" button on the .ENV viewer and one or two more supported addenda satisfies all reasonable expectations of WYSIWYG. The security/integrity issue will remain strictly within the eye of the beholder.


After that it will (again) come down to a business decision for appraisers. I think we all know how that decision will turn out.

George :

are you being the herald for Galactus again?

I hope what happens is that formsware companies and portal companies will start playing nicely together. If they would we would at least not have this problem.

Since i am born and raised in the south I am allowed a daddyism once in while;

My father used to say:

you can hope in one hand and pee in the other one:

guess which one fills up the fastest.