A New Year a New Fannie Mae Letter

Monday, January 6, 2014

I get it, appraising, especially residential-mortgage-use appraising, can be a thankless job. If you understand all that goes into properly developed reporting, it is hard to compete with the appraisers that perform poor due diligence and in turn, charge much less than the rest of us. They are great at checking boxes and making minimal commentary. They are rewarded for cutting corners, and appraisers that do the quality work are left at the margins. The new Fannie Mae Lender Letter may be a step in changing this.

Our costs to keep our licenses with the continuing education, the software, the equipment, the subscription services and everything else we need to just conduct business is expensive. Then you add in all the research we should be doing, the proper analysis of data and the time spent writing. Then you have to add in the fact that one appraiser can only truly do a limited amount of inspections and reports a week. What you end up with is a situation where an independent appraiser has to set a minimum fee that nets a profit that is economically feasible. This fee is typically higher than many AMCs are willing to pay to engage appraisers.

The forums and emails have been burning up the last few weeks with Fannie Mae's recent Lender Letter, Lender Letter LL-2013-10. Fannie Mae is dealing with how they want to handle data inconsistencies and how they will be dealing with appraisers that show pattern deficiencies with reporting data. I will admit that sometimes I am not that quick on the uptake, but the vitriol that I have seen on the various blogs, forums and email blasts has been overwhelmingly negative. The fact that appraisers are outraged and swimming in negativity is nothing new, but I really do not see why this is such a big deal. Fannie Mae is simply asking for consistency, and nothing more. The following is a portion of the referenced Lender letter:

    Fannie Mae will provide information directly to appraisers whose appraisal reports exhibit a pattern of minor inconsistencies, inaccuracies, or data anomalies. The intent and expectation of communicating these issues to appraisers is for training and educational purposes, and to provide them with an opportunity to improve their work. Future appraisal reports from those appraisers will be monitored to assess improvement (Fannie Mae, 2013).

Fannie Mae will reach out and contact appraisers when they see patterns of inconsistencies to try to improve on these issues. Why is that such a problem? Mistakes happen, and Fannie Mae is acknowledging that here. They are focusing on patterns of problems, in other words, reoccurring issues. This means that all that is happening is that they are seeing repetitive similar deficiencies in multiple reports. This harkens back to USPAP, and the requirement to abstain from errors that render a report misleading. In other words, per USPAP, "not to render appraisal services in a negligent or careless manner (Uniform Standards of Professional Appraisal Practice, 2014)"; this makes it nothing more than a professional reminder to improve data reporting.

They give the example of an appraiser changing condition ratings to fit the subject property of various reports. In very rare cases, this may happen legitimately, but only in the case of the appraiser discovering new information on the comparable not previously known. The assumption is that the appraiser has done enough research on the comparable to develop a reasonable opinion of condition and quality. If an appraiser is using comparable sales that they are not completely sure about, it is within their professional responsibility to state as much. That is what extraordinary assumptions are for, and this was still allowed the last time I read USPAP.

If you, as the appraiser, are unsure of property conditions then state it. The art of what we do lies in our effective narrative commentary to support our opinion. Transparent summaries include sharing both the strengths and weaknesses of the approaches and development of the report. Highlighting the weaknesses allows the appraiser to communicate the inherent risk associated with a said property and the surrounding market. Our jobs as appraisers are to be transparent and to reinforce that we considered all available and relevant information.

This may be a good thing for the profession as a whole. It is no secret that there are some appraisers that have embraced the Appraisal Management Company (AMC) model the lender-use side of appraising has gone to in recent years. This model has allowed some appraisers to capitalize on doing minimal work, and rewards cheap work. Cheap work means poor due diligence and sloppy practices. This may require these appraisers to improve or go away, which means better fees for those of us that price our services based on good due diligence.

References:
Fannie Mae. (2013, December 10). Retrieved from Fannie Mae: https://www.fanniemae.com/content/announcement/ll1310.pdf
Uniform Standards of Professional Appraisal Practice. (2014, January 1). USPAP. Retrieved from USPAP 2014-2015: http://www.uspap.org

Comments

Sure FNMA has come up with new guidelines...but they aren't set for appraisers who actually care and make important comments which normally would be overlooked by some computer. I really appreciate and salute those appraisers ! This whole profession is going to be controlled by computers which will read your reports....FNMA is looking at going to a CVR ( or CRV) whatever...and it's just going to go to more "number data" input so the computers can read things more efficiently....this whole business is going to hell in a hand basket and the law makers don't care and the Appraisal Institute really doesn't care.

The FNMA computer will only look for the checked boxes, it does not care how much you state in your comments. The writer says "That is what extraordinary assumptions are for" there is no person looking at the computer program and saying, oh, it settled last week and the only information the appraiser had was confirmed with the Realtor. Then, a month later the appraiser finds out the settlement never took place, or was for a different amount, or in one recent case Stevensville, MD the Realtor has never corrected the MLS sale of Four Million, for which the Realtor indicated included a house on 67 acres when in fact the Sales at Four million also included Four additional 5 acre waterfront lots. But we must all bend to the lowest denominator created in a computer program. I just cancelled my contract with one large AMC as they demand accuracy, consistency and response in 4 hours or before end of day which ever comes first.

Thanks for the reply:
"Then, a month later the appraiser finds out the settlement never took place, or was for a different amount, or in one recent case Stevensville, MD the Realtor has never corrected the MLS sale of Four Million, for which the Realtor indicated included a house on 67 acres when in fact the Sales at Four million also included Four additional 5 acre waterfront lots."

My question to that example is to ask: Would you not catch that when reviewing the deed(s)?

My blog deals specifically with the UAD codes for condition and quality. IN that vein, you are going to go with what you can prove, but when you find out additional information that could impact a previously used condition rating, you are at that crossroads of not being able to un-know something. You have to do the right thing, even if you think Fannie Mae is not reading it.

Woody Fincham, SRA

Thanks for the reply to the blog.

Yes, I believe it because regardless of what FNMA does or does not do, we are required to report in a transparent means. All of us still need to follow common sense and since we know they are looking at this it's rather simple to create narrative to apply to the situation. In my case I use the comps database in Wintotal with some commentary designed in my USL Documenter.

I do not know where Fannie Mae is trying to go in regards to the CVR, but even if that is the case, appraisers are still in the driver's seat with that model. It is incumbent on all appraisal professionals to be able to adapt and change with what clients need and require. If there can not be a synergy there, then those that disagree will need to find non-GSE work to do. No one is forced to do GSE related work.

Woody Fincham, SRA

Standard properties in my area are C3. I will think long and hard about using anything else moving forward unless it is an absolute clear-cut case. Otherwise, it's yet something else that can be used against us. They want consistency, they've got it. Subjectivity has been extracted. Open for interpretation has been removed. A C 2.6 is a 3. A C3.5 is a C3. No need to overthink or over-react to these demands.

RDAppraiser:
That seems like a common sense approach to me.

Woody Fincham, SRA

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