Wells Fargo RVS Desktop

[Zivka]

Thank you Brian for standing up to Wells and other "created" forms.

The banks goal is to pass something off as an appraisal without actually paying for one. The BPO's they are getting for $25 are not cutting it. They can't pass them off as an acceptable opinion of value to their investors. They can't get quality appraisals for $100. They aren't able to lump the AMC fee in with the what the appraiser is paid on the new RESPA. So....they "create" an appraisal that's not an appraisal because they said so. I can scream to the heavens that the sky is red, but me saying it doesn't make it so. It should be the same for Wells. Them saying it's not an appraisal doesn't make it so.

Where is their regulation? Where is USPAP and the Appraisal Standards Board? You mention in IL the appraiser is in hot water for doing one of these (as they should be). Why is the bank NOT in hot water? Why doesn't the Appraisal Standards Board knock on their door and say "sorry, can't do that."

They should be happy with using and owning the AMC's that have helped to dessimate our profession. The homeowners are charged at least 100% over what the appraiser is paid. The AMC (owned by the bank) created an additional revenue stream and it is still not enough.

Although I know you are a constant vocal supporter of our profession and of the regulations we adhere to, I also know you are one man screaming in a storm to be heard. m2:

What can WE do? What do YOU suggest?

 

[ddnma]

You mention in IL the appraiser is in hot water for doing one of these (as they should be).

I don't think that is necessarily true, there are situations where they can be completed and be in full compliance with all applicable laws and USPAP. Remember, your FNMA forms are not necessarily USPAP compliant as they stand. Remember who is responsible for the Scope of Work decision.

The scope of work is acceptable when it meets or exceeds:

>the expectations of parties who are regularly intended users for similar assignments; and
>what an appraiser’s peers’ actions would be in performing the same or a similar assignment.

The question becomes, is the fee reasonable for the expected amount of time required to complete this in a manner which is credible? I will leave that answer to each appraiser.

 

[Caligirl]

Homeowners will be entitled to it. Especially when the loan is denied.

The form does state that the intended use is for

internal risk analysis and/or mortgage lending purposes by the lender/client

Many seem to have missed that.

With regard to the above post, do you really think that the scope as detailed in the form would be something your peers consider acceptable for mortgage lending purposes? Just asking.

 

[Michigan CG]

.............
>what an appraiser’s peers’ actions would be in performing the same or a similar assignment.............

I do not consider all appraisers my peers. My peers would not even think about doing one of these reports. Peers may vary.

 

[ddnma]

With regard to the above post, do you really think that the scope as detailed in the form would be something your peers consider acceptable for mortgage lending purposes? Just asking.

"APPRAISER’S PEERS: other appraisers who have expertise and competency in a similar type of assignment."

If you don't complete desktops, you are probably not the peer of the appraiser who does, conversely, if you do, you may be.

I don't think it matters if "we" appraisers consider it acceptable for mortgage lending purposes. One size does not fit all.

What about a pre-foreclosure with a recent sale where the lender does not want to let the borrower know they have ordered a valuation product?

What about a $600,000 (market value) cash purchase three months ago and the owners want $100,000 or even $250,000 to buy that 2nd home they always wanted?

Is the appraiser going to say: "I know better, you have to have a full 1004 on this?"

 

[Zivka]

Let me clarify....I wrote "You mention in IL the appraiser is in hot water for doing one of these (as they should be)." I should have written the "appraiser CAN be in hot water" of course depending on a number of things (SOW, etc.).

I did not mean to say that automatically completeing one of the Wells forms gets you into hot water.

Personally, it is not worth my time, effort, experience and liability I would take upon myself.

Once again, each appraiser has to decide whether or not doing this type of work is worth it for him/her.

My main concern is what are our options. Appraisers as a whole are constantly to blame for the real estate crisis. They complain about appraisals being faulty, and now create forms that in my opinion are not sufficient to base hundreds of thousands of dollars of risk upon.

So I ask again: What can WE do? What do YOU suggest?

 

[Francois K. Gregoire]

Brian is not the only State Regulator weighing in. He is the only one willing to put his name on the opinions, however.

See Appraiser Active for some other regulator opinions.

 

[DWiley]

Why doesn't the Appraisal Standards Board knock on their door and say "sorry, can't do that."

The ASB hasn't/won't do that because they have no authority to take such an action. The authority of the ASB stems from the Bylaws of The Appraisal Foundation. The ASB is authorized to develop and promulgate USPAP. Period. The ASB has no enforcement authority.

Members of Congress pass laws, but policemen make the arrests.


What can the ASB do? They can issue an opinion or comment on the service in a manner similar to comment recently issued about the BPO Review service proposed by FA.

 

[Brian Weaver]

Danny is correct. Only the state can be the cop on this.

 

[William K]

So will the State be contacting Wells about their intentions to solicit Illinois State Licensed (Certified) Appraisers to accept APPRAISAL assignments which are in violation of USPAP?

If an institution solicited for someone to commit an aggravated crime I would think law enforcement might be contacting the one who is actually doing the soliciting and not just telling everyone they solicit that if you do the illegal deed we will prosecute.

At what point does solicitation to commit a crime come into play?