Non-lender Valuation: Consumers Should Tread Carefully

Saturday, January 18, 2014

Competition, in a free market, is a fierce catalyst: one that can effectively sort out the bad apples from the bunch. Capitalism works, it is simple when left unfettered and when all parties are ethical in their approach to business. It works until politicians, however well meaning they try to be, step in with a”solution”. Through the Dodd-Frank reform and the Andrew Cuomo created Home Valuation Code of Conduct that predates Dodd-Frank, congress effectively went anti-small business again. I liken this profession’s recent undermining by congress to how they saw to sort out the small-family farmers by paving the way for companies like Monsanto and ConAgra.

Competition is fierce in the valuation profession these days. For competition to work, it does require a level playing field. Presently, in residential valuation, there is no such thing as a level playing field. There are still lots of mortgage-use reports to do, but these reports are being filtered through appraisal management companies (AMCs). The AMC model chooses the cheapest appraisers competency is a distant second to cost, and like most things, you get what you pay for.

The quality of appraisal reports ordered thorough AMCs is getting bad enough that members of the Appraisal Foundation (TAF) have been quoted recently in the media with some interesting points. In a recent Chicago Tribune, John Brenan, director of appraisal issues, is quoted as stating:

"First, there is no additional revenue to fund AMCs, so the fee that an appraiser would earn is now divided between the AMC and the appraiser. Appraisers are making less money, and they have a new middleman they wind up working through. They're looking to engage the cheapest and fastest appraisers. So, we're seeing appraisals done across the country where the appraiser does not have what is, in fact, required under standards we write for geographic competency" (Glink & Tamkin, 2013).

By Mr. Brenan’s comments, it is obvious that enough emphasis was not placed on the things that matter. Instead of requiring the banks to pay for the alteration, a market was enhanced for non-appraisal entities to make money. Instead of enhancing the appraisal process, they provided a market that actually counters retaining well-qualified appraisers. It is a pretty big deal when an organization like TAF is drawing attention to the deficiencies found in the appraisal profession. One should give pause when history has proven repeatedly what happens when the collateral of mortgages is not properly vetted. The recent mortgage bust was partially created by issues with appraisals.

I would also supplement that most of the problems fell squarely on the big banks and how they retained and utilized appraisal services. Instead of requiring lenders to do the correct thing with retaining qualified appraisers, AMCs were given preference as a means to outsource the responsibility or at least the appearance of responsibility. The lenders got the advantage of AMCs seeking out minimally qualified appraisers that follow narrow scope of works (SOWs). Rather than hiring appraisers that are both competent and confident, they hire those that are prone to following without question. They effectively dictate to a large section of these appraisers how to do their job.

I know what you are thinking: Fincham your title says non-lender valuation, so why are you writing about Dodd-Frank and AMCs? Good question…

Non-lender valuation is the last bastion of market share that exists where appraisers can actually bill at a commensurate rate. These types of assignments will include appraisal reports performed for many situations such as wealth-management, divorce, and other litigation related needs. Oftentimes, intended users need to find the most qualified and experienced appraisers. Well-vetted experts are most applicable when testimony is needed. As litigation and divorce proceedings have evolved over the years appraisers are not needed as much for testimony; a report will satisfy the streamlined processes. In these situations, attorneys are not as involved with selecting appraisers as they were in the past.

Attorneys understood the need of retaining the best appraiser he or she could find. They needed someone that could write reports well enough to be seamless and defensible but also handle cross-examination in a trial or handle the craziness that can be a pre-trial deposition. It takes a good professional to write the report, but an even greater one to be effective on the stand or to help with pre-trial preparation. In the case of wealth management: to talk to an accountant and walk them through a report or analysis on the phone.
With less emphasis placed on the interview skills of the appraiser, many attorneys have relegated the retainer of an appraiser back to the client. Most consumers do not really understand what they need. The consumer makes a call, or does an internet search, to find an appraiser based on the only criteria that the do understand: cost. They also negate the importance of selecting the right professional in case they may need testimony later in time.

They can contact a well-qualified appraiser that understands the work involved with their situational needs, or they can contact an appraiser that does mostly government sponsored enterprise (GSE) work. Appraisers that do mostly lender-use work within a very confined box, and unless they have a background in non-lender work, will likely not have the problem solving skills needed for thinking outside of that box. AMCs often provide such detailed instructions to their roster appraisers, that the appraiser is boxed into a very narrow scope of work (SOW). These appraisers are experts at meeting the SOW established with the AMC. However, what happens when these narrow SOWs are removed? You introduce someone that specializes in filling out a form to a world full of variables and possibilities.

An appraiser is only as valuable as their experiences allow them to be. Part of this value is knowing and recognizing the strengths and weaknesses of the approaches to value. An even bigger part is thinking in the abstract and knowing that in trials and depositions, an attorney will exploit a weakness in a report. They will discredit an otherwise good appraiser if that appraiser is incapable of dealing with questioning effectively. Appraisers that concentrate solely on mortgage-use reports have no background to be effective in these types of situations.

So How Does Dodd-Frank Tie In?

Therein lies my problem with the AMC bred and conditioned appraisers. The fees have been beaten down so low for mortgage work that the appraisers that only do AMC related work are now trying to compete in the more lucrative non-lender market. Here we have members of TAF acknowledging that the lender market is using less-than-optimal appraisers. That alone is enough to make a normal person pause and pay attention. This was Washington’s answer to a problem they did not understand, and by stepping in, they created waves that extend beyond their intended design. They destabilized the market for established and trusted professionals.
These same mortgage-use appraisers have discovered that non-lender work pays better: in some cases, much better. They capitalize on the naivety of the consumer base. In a sense, they are capitalizing on a competitive advantage, but only an artificial one that was created by the meddling of politicians. In a very real way, Dodd-Frank is now affecting the valuation profession outside of the mortgage business.

In that same Chicago Tribune article, David Bunton the president of TAF stated "Most appraisers not going to turn around a top quality appraisal in 24 hours, for half of the normal fee. So you get people who are less experienced, who have less business clientele, and they may end up driving 4 to 6 hours for $150. We're concerned about quality" (Glink & Tamkin, 2013).

Mr. Bunton, we are all concerned over quality. Those of us that have refined our toolsets and experience are being passed over for appraisers that have been subsidized by a flawed mortgage market that is propped up by the AMC model. The weak links of that subset of appraisers are now matriculating into non-lender work. In a way, the biggest user of appraisal services, the mortgage companies have once again undermined the appraisal process. By law, appraisers are required to abide by USPAP to preserve the public trust. Until lenders and AMCs are required to follow it, it will remain nothing more than a very effective tool to make those that claim to be ethical blend in with those of us that actually are beholden to our professional integrity.

The bottom line for appraisers, attempt to educate your attorney clients and colleagues on the differences between what a true professional appraiser is and what a primary mortgage-use appraiser is. Reach out and network with your bar associations and other professional organizations. Distinguish yourselves from the group through education and networking opportunities.

The bottom line for consumers: be careful whom you attempt to retain. Be willing to ask an appraiser why they are a better pick than the other appraisers. Be willing to check references and ask for a resume. Take your time and make sure this appraiser is well qualified and not just minimally qualified. The inverse to you using a well qualified can actually cost you more money. If you end up in a trial, the cost to have your attorney reorder a better report, or pay a well qualified appraiser to assist in pre-trial analysis. Even worse, you may find that across the courtroom, your opponent hired the appraiser you should have, and now your mortgage-use appraiser will be in contrast to a superior professional.

Works Cited
Glink, I., & Tamkin, S. (2013, December 26). How do you get a great appraisal? Try eliminating the AMC. Retrieved from Chicago Tribune real estate: http://www.chicagotribune.com/classified/realestate/sns-201312221330--tm...

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Ongoing give accomplishment in Potter’s party discusses checking out multiple helpings of how usually the Ancient Beringians lasted, including adjustments throughout their particular diets in the foreseeable future, how several used residence plants, and the direction they organized theirselves. www.todaynewsjournal.com
That burping is a lot about girl luck. There's several valve together with the intestinal that indiscriminately elements and ends providing air to arrive out. Pediatric rns, doctors not forgetting baby specialists opt to think that individuals have specific begin increasing the size of burping, but just what it comes as small as is a great deal of lady fortune. www.1stbabby.com
One rest is which iron by means of infant formula bring about constipation by means of babies. This is the common rest, and it proceeds from mothers just what individuals acquire iron and turn into constipated. It's dangerous because playing golf iron deficit through toddlers that grows early by means of life are often associated with the aid of developmental delays. www.allbabby.com
Yet another is which breast-fed toddlers who've received some level of sensitivity to protein within your mother's milk could possibly be taken separate breast acquire but practically all babies with the aid of milk necessary protein sums allergy are often successfully breast-fed without any going in opposition to hypoallergenic prescription medications. www.bestbabby.com
Actually, I think it's several myth which parents take notice on negative advice. My experience is that parents' your health literacy is first rate. But you'll find increasingly a lot of misinformation available, so daddies and parents do be mindful. www.probabby.com
Not to cover, of way, there are usually every depth about for what reason babies poop each and every time they take in, why poop makes sense electric-green sometimes those were things I learned within the practical helpings of doing work for twenty decades in huge children's hospital inside the land. www.vipbabby.com
Vendor training course arrangement is some sort of financing set up ın which usually finance exists for the shoppers since some revenue, online marketing and advertising & value closing method. Country, point out, city and municipality finance is known as public purchase. It will be anxious with usually the budgeting method. www.1stfinancehut.com
Each distinct company works on the unique design of marketing relative to kinds regarding focus they have for his / her or her's business. Advertising a great enterprise will be purely while using the products. Making the particular payment program and wedding party users and also attendents overview is not really enough. Company should really put the particular payment program into shift and follow it up not forgetting evaluate that again occasionally. www.vipfinancepalace.com
Home enterprise finance serves as a stepping stone for all of us small organizations. With home-based business finance particular person can minimize the situation of resources that borrower comes across during the particular bosses. You will find two main varieties of finance on the market to tiny industry. www.efinancetown.com
The fellas I'm linked to, the fellows I manage and the ones I have a look at when Therefore i am out there shopping needs to have some enamel yanked than pick from a swimwear, choose several shirt, and, for which matter, go shopping for sweat socks. An illustration with this this mind set is David p Bentler, several 27-year-old monetary adviser simply by Smith Barney, who mentioned that retailer shopping "is in reality torture. ins "Going to be able to stores, contemplating multiple essential things? www.shoppingjoint.com
I'd persistently assumed that your was find out about service that Michael jordan, Donald Trump not forgetting Tom Sail vacation use towards attire themselves relating to busy life span as zillionaires. Many menswear retailers offers private service if you spend a great deal of money simply by their organizations. www.eshoppingboss.com
But Just about everyone has recently learned that the same thing is on the market to regular those that less astronomical income, retailphobics who choose to avoid shopping to have but at the same time don't rely on the judgment and want the particular non-public attention you ought not get retailer shopping on the web. www.urbanshoppingdiary.com
He works over a company called Tom Brandon, a confidentially owned business founded by means of Nashville by means of 1966 that wont advertise possesses recommendation to get its buyers. (The corporate also really does could office clothes, but lot's regarding its shoppers certainly are a mans. )#)#) www.futureshoppingclub.com
Shopkick Inc., the retailer shopping returns transportable application favored by big-box eateries, is possessing Main Saint. The Palo Alto, Calif. -based goods firm could be wooing neighborhood retailers as a result of coffee stores to bakeries toward clothing retailers in 10 villages, cities, which includes Chicago, il, in a few bid toward expand the girl reach. www.freeshoppingbite.com
Usually the shopping iphone app, introduced continue August, positive factors customers with the aid of points called "kicks" when it comes to entering several store. It is actually akin to get a paper help punch credit card even over a smart cell, but shoppers need not purchase anything to get points. www.eshoppingroad.com
A day-to-day prayer confession could may include: "The Scriptures say that health serves as a promise not forgetting an inheritance for many who love not forgetting serve god, and we all regards regarding bringing sickness definately not our kids, for repairing health in your prospects, www.1stparents.com
1. managing their serious wounds, and introducing them as a result of destruction. We pray they can not turned into depressed and discouraged, they can be in health and well-being, a Word provides strength with their our bones, and that most those can fit these. inches www.parentstutorial.com
We need our kids to choose their fellow workers wisely and socialize together with individuals discuss his or perhaps her's values and sometimes will not encourage them to become during wrong and dangerous circumstances. We desire to be able to be confident www.parentsside.com
A prayer confession example is frequently: "We wish which our youngsters could become wise at any time choosing his / her or her's close friends. Regards, The almighty, for choosing self-esteem not forgetting confidence, they can not acquire something just due to the fact crowd does about it and that they will certainly not let many other pressure express their judgement making. www.parentsstory.com
in who they are and to aid with creating choices depending upon just what many know could be right rather than from insecurity why not a need when it comes to acceptance. Typical, we have the ability to pray for our children, his / her or her's close friends, and all others who may have an influence on their lives. www.parentsfuture.com
Within the past few five numerous decades, maybe a small bit more time, increasingly golfers on the professional tours are often switching toward belly not forgetting long putters understanding that also provides led more and more amateurs to select suit enable the much more time shafted putters a go. www.1stsportstutor.com
We are of the opinion very strongly that belly not forgetting long putters should go on to get popular with all the pros and also amateurs understanding that also the particular overwhelming is going to be amateurs could possibly be testing by means of or through the use of these putters consistently. www.mysportscaptain.com

Bulls cardiovascular system Eddy Curry need to remain experience acceptable about ones own future. Curry, who’s expecting message about when an elevated heart may help keep him from the comfort of signing a wonderful contract file format, was noticed Monday you will find a innovative Bentley positioned at Bentley The old timepieces Coast. But what exactly really noticed Curry's vision ball was every one of the blue convertible Ferrari parked ahead of the upscale supplier, cybershoppingwatch.com
Shopping investing programs are receiving comparison-shopping perfectly in to a more prospective proposition. Referred to as 'bots' regarding techno-speak, the web sites work straight away: The particular person types inside request, and every one of the bot activities to some other sites locate similar or perhaps matching factors. allshoppingfun.com