Agre- sales fiannced using a waier are NOT identified as such ,unlike every other sale which is identified as conventional, FHA, VA, cash - so ther is no way for appraisers, investors, or anybody to track the prices of sales sold using waivers to compare them to other sales.
G Hatch keeps going on about how lenders only need to know if a sale is grossly overvalued - 1) that is really bad news if true, for individual homes and their owners could fast be underwater and affect on markets - 2) the lenders should not be the only ones in control of the valuation since they are salespeople, they are not the investors buying/holding the loan and they are not the taxpayers backing the loan - the waiver, as far as i know, is the first large scale shift in res mortgage Fannie/freddie loans where the lender decides the value ( and yes we f** know by now they also use an AVM ) - but despite using an AVM, the reality is the lender decided the subject value !! that is the old mortgage brokers wet dream -
the bottom line about waivers is they evade the regulations put on appraisals wrt predetermined values by not using an appraisal
Idk how they convinced the regulators to accept that - i suppose with the lower risk speech - but they make their own risk studies so who is to say - plus, their risk studies leaveout the impacts on markets on sales financed with waivers, plus, again, if they are so certain the risk is so low, why aren't the lenders made to back these waiver valuations with reps and warranties? A lender must back an appraisal with reps and warranties for the collateral in the loan, but they do not do that on a waiver.- it falls 100% on the tax payer. One would think if the Waiver was such a low risk, the lender would have no problem with the reps and warranties on the value ( sarcasm). The lender must provide reps and a warranty on the value of an appraisal, but not for a waiver. A different set of rules.