What does it Mean to Protect the Public Trust

[Zoe]

Nobody in the whole federally regulated lending world holds a candle to the power that panel has.

American bankers association looks like a mosquito in power compared to that appraisal bias panel .

 

[djd09]

So you're saying you still have an active license and you are performing appraisals? Because I don't believe you.

why would i care what you believe...you think the mortgage brokers have been cut out of the loop #fastapp

 

[Zoe]

Name the entity. Nobody holds a candle to that appraisal bias panel.

 

[George Hatch]

why would i care what you believe...you think the mortgage brokers have been cut out of the loop #fastapp

Yeah, I already knew the answer when I "asked" the question.

 

[djd09]

yep keep trolling the same independent boots on ground appraisers...just like crn told you to

 

[alebrewer]

In counterpoint, if a state looked at an appraisal and didn't take note of other problems those problems would persist in that appraiser's work. Not to mention the point that just because a layperson didn't notice the true cause of the problem doesn't mean it wasn't there. The state's obligation in that one complaint isn't limited to that one complaint.

I think where people go off the deep end on deficiencies is when they assume every deficiency is equally serious and merits the same reaction. That is clearly not the case.

Most assuredly, that is a consideration. Had the person not filed the bogus complaint against 'low value', however, the state would never had access to that report. I'm not condoning lazy or incompetent behavior - and maybe the point about all deficiencies not being the same is part of the solution - but I'm just defensive of folks who maybe are rushing a bit too much, yet get penalized by the state for some minor infraction the investigators would otherwise not had knowledge of.

 

[Mike Ault]

Most assuredly, that is a consideration. Had the person not filed the bogus complaint against 'low value', however, the state would never had access to that report. I'm not condoning lazy or incompetent behavior - and maybe the point about all deficiencies not being the same is part of the solution - but I'm just defensive of folks who maybe are rushing a bit too much, yet get penalized by the state for some minor infraction the investigators would otherwise not had knowledge of.

Remember the (unnamed) bank who decided to send batches of appraisals to the state appraisal boards alleging "possible USPAP violations", and use the results of those free investigations to force repurchases of nonperforming loans? It seems that strategy has been recently resurrected by the GSE's with their frivolous, automated complaints to the state boards as well.

 

[George Hatch]

I don't think minor housekeeping infractions are worth anything more than a phone call or a note. Certainly not a fine or public reproval (name and shame). Those don't usually occur as a result of intent, but because the appraiser literally doesn't know any better. A little explanation specific to that error or omission will be sufficient for most first time offenders. If they end up coming back for the same thing THEN its time to escalate the response.

If the state could identify the 10 most common housekeeping errors they could write up a 1-pg what/why instructional on each, post them on their website and include a link in the don't-do-it-again letters they send out.

Most appraisers I've ever interacted with - even the donkeys - truly believe their work is just as good as anyone else's. IMO appealing to their intent is the most effective avenue of approach. For the first time offenders, anyway. Making everyone paranoid via uncertainty is hugely counterproductive. 2/3 of the opposition on this forum to licensing and appraisal standards is the result of people being unsure of where their work actually stands WRT the requirements that the state boards are trying to enforce.

 

[Terrel L. Shields]

appraisers were working off contingent engagements and contingent fees?

Where? Never seen it.

Problem I have is we are supposed to write the report so the user(s) can understand it. But if a non intended user doesn't understand it they can still turn it in to the state

That part of regulation is an absurdity which apparently everyone in 1990 was willing to go along with even if the "intended user" is clearly stated. No one except the intended user should be allowed to file a complaint.

Fannie clearly intends for a large number of unidentified users to use the appraisal report for a number of unidentified uses.

too true

FNMA is trying to crush independence by supporting some of the worst offenders, they are just scapegoating. They get bailed out anyhow.

double too true

you think the mortgage brokers have been cut out of the loop

Too many times the borrower or broker can impact the selection of the appraiser. The honest loan officer might want the most competent one. The loan originator - who, unlike the LO, is paid from commission -

 

[George Hatch]

When I started teaching in 1996 there were a whole lot of course participants who took it personally when I was showing them in USPAP where it says that contingent engagement and contingent compensation were prohibited. Not to mention the pushback I got over the problems with the garden variety comp checks of the day.

By that point some appraisers knew, some didn't and thought I was making it up. Same as I get now every time I show someone here something they don't want to "see".