Voice of the Appraiser In-Depth Report

[djd09]

I knew this was going to be a cluster**** 5 years ago when the snake oil scumbags that push and defend these things were being flown around to state board stakeholder meetings.

State boards can't tell the public that they only oversee half of the appraisal process. Not sure how some of you can't understand that.

just goes to show you what kind of bottom feeders we are dealing with...ask paschal

 

[George Hatch]

Rather than change the subject, just address the concerns above.

The lender engaged the PDC, presumably the same way they engaged the appraiser - either directly or via an AMC. The fact that you were engaged or directly employed on staff by the lender doesn't lead to the presumption that your work might be biased. How you would argue differently for the PDC will require a break in logic and consistency.

If you were taking info from another appraisal report (provided by the lender), how would you resolve this question? You'd check their work against your other data sources, right? In lieu of info to the contrary you would probably have no other reason to doubt and would probably proceed. Leastwise that's the argument you would present in your defense.

Let's not forget the test for the reasonableness of the SOW decision (which is what we're discussing here), has to meet both tests:

What the users of this type of assignment expect, and​

What the appraisers who perform this type of assignment would do.​

As in, not necessarily what all other appraisers would do, or what any one appraiser would do. The standard is written that way for cause, not as an accident or oversight to screw appraisers over for their fees.

I would have thought 100% of this comment would go without saying, which is why I skipped directly to the appraiser's solution.

 

[George Hatch]

Amen!

You're more than welcome to rebut my comment above, too.

 

[George Hatch]

The hardwired verbiage in the hybrid 1004 form directly addresses these issues. There's no reason to engage in the strawman argument that the intended user is somehow unaware of the additional assumptions the appraiser is using in this assignment. Somehow unaware of what the appraiser did/didn't do in their own SOW.

The form wasn't developed by appraisers and wasn't developed in order to cheat the lender or the secondary market users. The GSEs built this program and the form that goes with it, including deliberately wording their disclosures in this manner. The lenders (and the GSEs) can't hardly argue the appraiser is cheating them by appraising to the GSE specs they're choosing to use in these transactions. If they had a problem with the workproduct they're using then they should have ordered a conventional 1004.

 

[djd09]

tell them...there is no party like a 15th st party

 

[CGinMN]

The lender engaged the PDC, presumably the same way they engaged the appraiser - either directly or via an AMC. The fact that you were engaged or directly employed on staff by the lender doesn't lead to the presumption that your work might be biased. How you would argue differently for the PDC will require a break in logic and consistency.

It is not about the presumption of bias. It is about confirming data that is coming from a disinterested party.

If you were taking info from another appraisal report (provided by the lender), how would you resolve this question? You'd check their work against your other data sources, right? In lieu of info to the contrary you would probably have no other reason to doubt and would probably proceed. Leastwise that's the argument you would present in your defense.

The 2055 has a SOW statement that states.

A hybrid has no such requirement, other than what is implied by Cert 10, to which there seems to be a lack of clarity among appraisers and users.

Let's not forget the test for the reasonableness of the SOW decision (which is what we're discussing here), has to meet both tests:

What the users of this type of assignment expect, and​

What the appraisers who perform this type of assignment would do.​

Unfortunately, what users expect and what appraisers do for this assignment are both inconsistent with what I see as the appraiser's requirement to verify.

IRL and going back many years, 95% of all appraisers never once fretted the lack of personal measurements and interior inspections on any 2055 they ever did. It's far too late for them to be clutching their pearls and taking to the fainting couch over doing the same - and being consistent with their actions - with these.

I never did a 2055. But I've heard in hindsight that appraisers were doing them incorrectly all along because they didn't have the necessary data to verify the interior condition, which was never explicitly stated but was retroactively implied... despite what any exterior observation was telling them and in lieu of info to the contrary.

 

[George Hatch]

tell them...there is no party like a 15th st party

[shrugs] Maybe Trump47 will proceed with his downsizing quest. Maybe his administration will kick the GSEs out of that status and they'll become garden variety commercial enterprises. Free of their govt-mandated role to promote home ownership regardless of profitability.

I don't know what you are capable of speculating will occur in the wake of that development, but I can speculate upon several possibilities. None of which will lead to the outcomes appraisers might desire.

 

[Sadie]

So much for the theory that they can't blame you for something you did not complete.

View attachment 93717View attachment 93718

That was always the problem with these alternative products. When they first came out, we were told, if there is a bad property inspector eventually it will be noticed and they won't get assignments. I have seen some truly awful property inspections, No way would I put by signature on any of that crap.

 

[CGinMN]

The hardwired verbiage in the hybrid 1004 form directly addresses these issues. There's no reason to engage in the strawman argument that the intended user is somehow unaware of the additional assumptions the appraiser is using in this assignment. Somehow unaware of what the appraiser did/didn't do in their own SOW.

The form wasn't developed by appraisers and wasn't developed in order to cheat the lender or the secondary market users. The GSEs built this program and the form that goes with it, including deliberately wording their disclosures in this manner. The lenders (and the GSEs) can't hardly argue the appraiser is cheating them by appraising to the GSE specs they're choosing to use in these transactions. If they had a problem with the workproduct they're using then they should have ordered a conventional 1004.

View attachment 93764

View attachment 93766

C'mon, you should know better. GSE specs are deliberately written in a manner, not to provide clear instructions to the users and to the appraiser, but to allow the GSEs to shift liability back on the lender and appraiser. Why would they design it any other way?

 

[George Hatch]

It is not about the presumption of bias. It is about confirming data that is coming from a disinterested party.

The 2055 has a SOW statement that states.
View attachment 93765
A hybrid has no such requirement, other than what is implied by Cert 10, to which there seems to be a lack of clarity among appraisers and users.

Unfortunately, what users expect and what appraisers do for this assignment are both inconsistent with what I see as the appraiser's requirement to verify.

I never did a 2055. But I've heard in hindsight that appraisers were doing them incorrectly all along because they didn't have the necessary data to verify the interior condition, which was never explicitly stated but was retroactively implied... despite what any exterior observation was telling them and in lieu of info to the contrary.

Again, the user-driven requirements are being set forth by these users. In writing. They are free to add or subtract from their supplemental options menu any time they want. Nor is there any conflicting standard in USPAP which imposes a zero defect expectation on the accuracy of any 3rd party info from any source, disinterested or not.

Do the GSEs have the right to build their program this way or not? That is the question.