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We need to clean up FNMA and Freddy

You were probably dropped from the roster right then and there.... or at least move down to low man on the totem pole.


Your dedication to the profession, continuing education to better yourself, expertise, and all the years of knowledge... that does not matter to AMC's.
Mostly just quit responding to them. Then FNMA/Freddie included them in their preferred partner programs.
 
Mostly just quit responding to them. Then FNMA/Freddie included them in their preferred partner programs.
Conflict of interest..... yeah, AMC's are waaayyy better than dealing with mortgage brokers. Phhhffft.
 
Conflict of interest..... yeah, AMC's are waaayyy better than dealing with mortgage brokers. Phhhffft.
"Better" lies in the eye of the beholder. I'm sure many of these lenders would be quite happy to go back to MB-select so that they could disavow any involvement at all with the appraisal. Like they did before, largely successfully. The lenders are not dealing via direct engagement or delegating to AMCs because they want to, but because they have no alternatives.

If the AMCs get cut off the lenders who have been using them won't have any alternatives left except to operate via direct engagement. They DEFINITELY won't consider that to be better.
 
There just simply is no way to talk one's self out of an accusation that the borrower is - at the very least - an intended user when he/she is paying the appraiser directly for the service. Back in the day it was VERY common for the MB's to advise their clients to offer additional incentives to elicit more favorable valuations. I've had homeowners offer more money, offer things of value, sexual favors - you name it. I'm telling you - as corrupt as it is today, it's nothing compared to PTDF (prior to Dodd-Frank).
Dang..... you must be good looking.... I only got offered a water or a soda.
 
The lender (or its authorized agent)

  • must establish policies and procedures to ensure that qualified individuals are being selected in accordance with Fannie Mae requirements, including the Appraiser Independence Requirements.
  • must ensure that an appraiser has demonstrated the ability to perform high-quality appraisals before using an appraiser’s services. The quality of an appraiser’s work is a key criterion that must be used in determining which appraiser the lender (or its authorized agent) uses for its assignments. The requirement for an appraiser to produce a high-quality work product must always outweigh fee or turnaround time considerations.
Delegating these responsibilities to a third party does not relieve the lender of its responsibilities related to the appraisal or the value, condition, and marketability of the property. See B4-1.3-12, Appraisal Quality Matters, for information related to ongoing review of appraisals.


How did any AMC you may be on do this before using your services?
 
The lender (or its authorized agent)

  • must establish policies and procedures to ensure that qualified individuals are being selected in accordance with Fannie Mae requirements, including the Appraiser Independence Requirements.
  • must ensure that an appraiser has demonstrated the ability to perform high-quality appraisals before using an appraiser’s services. The quality of an appraiser’s work is a key criterion that must be used in determining which appraiser the lender (or its authorized agent) uses for its assignments. The requirement for an appraiser to produce a high-quality work product must always outweigh fee or turnaround time considerations.
Delegating these responsibilities to a third party does not relieve the lender of its responsibilities related to the appraisal or the value, condition, and marketability of the property. See B4-1.3-12, Appraisal Quality Matters, for information related to ongoing review of appraisals.


How did any AMC you may be on do this before using your services?
Short answer? They don't - neither AMC's or lenders. How does reviewing a couple of samples of redacted appraisals with no adjustments provide anyone with an assurance of an appraiser being able to perform 'high-quality' appraisals?
 
Short answer? They don't - neither AMC's or lenders. How does reviewing a couple of samples of redacted appraisals with no adjustments provide anyone with an assurance of an appraiser being able to perform 'high-quality' appraisals?
It probably does not.

So how does one comply with the law.

The law clearly states the fact an individual has a license is not in itself enough to place someone on an approved list or use them.

An institution also is responsible for ensuring that a third party selects an appraiser or a
person to perform an evaluation who is competent and independent, has the requisite experience
and training for the assignment, and thorough knowledge of the subject property’s market.
Appraisers must be appropriately certified or licensed, but this minimum credentialing
requirement, although necessary, is not sufficient to determine that an appraiser is competent to
perform an assignment for a particular property or geographic market.


So how do you suggest complying with the law, outside of sample work?
 
It probably does not.

So how does one comply with the law.

The law clearly states the fact an individual has a license is not in itself enough to place someone on an approved list or use them.

An institution also is responsible for ensuring that a third party selects an appraiser or a
person to perform an evaluation who is competent and independent, has the requisite experience
and training for the assignment, and thorough knowledge of the subject property’s market.
Appraisers must be appropriately certified or licensed, but this minimum credentialing
requirement, although necessary, is not sufficient to determine that an appraiser is competent to
perform an assignment for a particular property or geographic market.


So how do you suggest complying with the law, outside of sample work?
Prior to engagement on an atypical assignment? There is none. In all the audits I've been through, however, the practice of reviewing sample appraisals has been sufficient to demonstrate compliance.
 
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