Appraisal Quality vs. Appraisal Independence

Monday, March 18, 2013

The interagency appraisal and evaluation guidelines are very clear, (when) “communicating the noted deficiencies to and requesting correction of such deficiencies by the appraiser or person who prepared the evaluation, an institution should implement adequate internal controls to ensure that such communications do not result in any coercion or undue influence on the appraiser or person who performed the evaluation” That sounds simple enough, right? So why is it that so many appraisers are talking about appraiser independence related to appraisal revision requests?

Appraiser independence issues were once relegated to the type of strong-arming appraisers received when submitting a “low value” but now it seems there is a new form of appraiser independence emerging, from the ranks of the appraisers (and non-appraisers) reviewing the appraiser’s reports.

Appraisers have indicated that these requests for revisions and comments based on automated review systems are not in compliance with appraisal independence requirements because of how the requests are being communicated. They state that the reviewers are suggesting that if the revisions are not made they will take them off the list of approved appraisers or lower their “score” so they do not receive future assignments.

But what if there are material deficiencies in the appraisal report, shouldn’t the appraisers be fixing them or more appropriately, should there be deficiencies at all in a report prepared by a professional appraiser if they were adequately performing their job?

There has been so much discussion over the years among appraisers, appraisal reviewers and underwriters about what the “guidelines” are and are not, that it has become difficult to determine a well done, quality appraisal report. The Fannie Mae and Freddie Mac guidelines have been interpreted by some as “law” rather than suggestions or guidelines and underwriters and reviewers have forced appraisers to use comparables and make comments that “fit into the box” rather than what they believe to be the best, most comparable sales or the most appropriate commentary.

Now introduce “client specific instructions” and the determination of a quality appraisal just got exponentially more difficult. Non-appraisers in the spirit of improving appraisal quality have added erroneous requirements such as pictures of running water, the “photo-shopping” out family portraits from interior pictures or pictures of the address of the house. Is this really leading to a higher quality appraisal? Are these really significant deficiencies in appraisals? Do these items really contribute to a quality appraisal and are they worthy of the tension created between appraisers and the reviewers?

The Interagency Appraisal and Evaluation Guidelines state “an institution should not directly or indirectly coerce, influence, or otherwise encourage an appraiser or a person who performs an evaluation to misstate or misrepresent the value of the property. Consistent with its policies and procedures, an institution also may request the appraiser or person who performs an evaluation to, consider additional information about the subject property or about comparable properties, provide additional supporting information about the basis for a valuation and correct factual errors in an appraisal.”

If reviewers are applying data or erroneous standards to the report like throwing mud against a wall hoping something will stick, or demanding appraisers change immaterial items on the appraisal or face consequences, then it is pressure and inappropriate.

If the reviewer of the report can identify relevant and material deficiencies, such as more recent, similar and proximate sales not considered, then the appraiser missed something and they should promptly correct the deficiency.

Appraisers have to stand up and take professional responsibility for developing a credible, USPAP compliant appraisal report. They must take the time to explain why they do things so the intended user understands how they came to their conclusions. If someone reading the report doesn't understand, then it is not pressure, it is required under Standard Rule 2-2bviii and the appraiser hasn’t done their job.

It’s time for underwriters and reviewers to focus on what matters in an appraisal, compliance with USPAP, and not an altered version of the agency guidelines or a check list of arbitrary and meaningless specific requirements. It is also time for all appraisers to become the professionals that the industry is demanding and submit credible, USPAP compliant appraisal reports. When this happens, the discussion of appraisal independence will shift to appraisal quality, right where it should be.

Have any comments or would you like to submit content of your own? Email Jim@appraisalbuzz.com

Comments

Tony,I must say, really enjoyed reading your article. We are definitely coming to similar conclusions based on the current events within the industry.

In most cases an appraiser would not have been reveiwed if the report had made value.The appraiser knows problems are going to result so has done due dillegence before it was submitted. By this fact alone, resulting trivial complaints and unsupported requests for revisions are lender pressure to come into compliance, to join the team and to make value.The lender AMC business model is to make money efficiently by reselling the loan. There is clear evidence that this is true in the appraisals that are not reviewed. There is almost no dialogue and the appraisal is accepted anyway. The appraiser has made them happy by making value and accepting the risk of a later loan failure. Except for gross math errors by the appraiser the lender is at least partly off of the hook because of the appraisers risk tolerance.This is the ideal situation for the lender so there is motivation to pressure the appraiser by unneccessary revision requests to get her to assume the risk. We can't make any money responding to requests for revision.The flaw in this business model for both the lender and the appraiser is that the appraiser's insurance is only effective as long as he carries it. If the appraiser retires and doesn't buy insurance the lender"s only coverage is the appraisers assets. You have become enslaved. The only way you can quit is to have no assets to lose or to be able to buy insurance for 5-7 years after you retire or change jobs.

The disconnect between what the employees and appraiser brokers of financial lending institutions think they need in an appraisal report and what a state-licensed appraiser must include in an appraisal report is causing some major problems within the residential mortgage lending industry.Thanks Appraisal Buzz for sharing Tony's obvious expertise on this topic!Darwin Ernst, SRA

I applaud Mr. Pistilli`s ``Why can`t we all just get along`` attitude. Most Appraisers are offended when asked to explain their results or provide additional commentary to help a reader digest the appraisal report. Clients are now actually thirsty for the reasoning and data behind the process. Once Appraisers figure out that the client and or their Reviewers aren’t the enemy things will go much smoother.

 A reviewer is hired to find faults- that is what they do, and that is what they get paid for. Put yourself in their shoes for a minute. They would not keep their job if they let every report slide under the radar. I agree that the "running" water shots, or the reviewer telling me I am not allowed to give any "weight to a listing" is a waste of time. The reviewers take a nice size $$ chunk out of our fees and I bet they make more money on a hourly basis than appraisers do. Id rather give a portion of my fees for a real appraiser to review my work than a non-licensed individual.

Another plea for "quality" appraisals with no clear definition of what quality is.  Right now, appraisers, also lacking a specific definition of quality, can only be as thorough in their development as Standard Rule 1-4 requires and do their best to communicate the results in spite of UAD and pages of narrative separated from the little Fannie Mae boxes.  We simply do not know what you want, but we know nobody wants what we have when it comes to secondary mortgage market work.Can't disagree too much Mr. Pistilli, but I still define quality appraising as what it is not.  It is not cheap and it is not fast.  I tell that to the AMCs claiming to be desperately searching for quality in the appraisals they order, and they never call back. I would have entitled the article Appraisal Quality vs Cheap and Fast Lenders because they just don't want to pay the appraiser to take the time to a thorough job that are at least two prerequisites to produce quality.It does sound like step in the right direction if the profession were to rid itself of all of this meaningless hastle and review by unqualified AMC employees or licensed reviewers who are paid 1/2 or less of what the original appraisal fee was. 

At the end of the day the real issue becomes compensation. Time is money. Fees are down, the scope of work is up. The only way to adjust for this is by doing an increased volume of work. The problem with the ever evolving scope of work becomes the time it takes to go back and make the client specific revisions. Most of the silly revision requests come from the decision makers that actually know much less about the appraisal process than those that are completing the report. Ulitmately appraisers need to band together so we can effectively stand up to those that are continuosly making the process unnecessarily inefficient while not paying an adequate rate for professional services. I will make any semi-reasonable revision as long as I receive a "full" fee but when you pay a discounted fee, you receive a discounted product, thus is capitalism. We can still do this without the AMC's, they can not do this without us. 

The choir of appraisers already knows how to produce quality; however, Tony appropriately points out to those wishing to tweak the voice of the appraiser through incredulous demands need to clean out their ears and listen, rather than hear through an artificial filter that accepts only certain sounds. Could the real issue be that since some clients don't hear what they want to hear, they have trouble hearing?

"should there be deficiencies at all if appraisers were doing there job?"  Wrong question.  Correct question: "Should Lenders be held responsible under Federal and State Laws for the actions of their Captive, or Contracted AMCs who continue rewarding Incompetence while thousands of 10-15-20-30 year Professional, Competent Appraisers who rightly demand being compensated as Professionals and refuse 12, 24, and 48 hour TAT assignment conditions?"   The OCC says yes, the FDIC says yes, State Attorneys-general who are tasked with enforcement of Dodd-Frank nod their heads. The farce continues while NO enforcement of existing Laws governing the actions of Lenders and AMCS in selection of incompetent appraisers enables those whose licenses should have been revoked years ago.  

I have been an appraiser for 36 years, the last 20 as a cerified general.  The biggest problem many appraisers have is their inability to properly write a complete sentence.  This in turn leads to inadequate, vague and often times a gibberish explanation that just leads to more questions.  I owned a large appraisal operation in the 1980' and 1990's and would often times require an appraiser to attend a local community college english remediation class if they wished to have a future in my organization.  Most did and their work showed a great improvement.The second problem, reliance on boiler plate.  Folks, get away from it. If each property is unique, as most of us claim, then shouldn't each appraisal be unique?  When I get review assignments, often times, due to the extensive use of boiler plate, I don't even know if the appraiser has even seen the subject.  This just leads to a lot more questions and increased irritation for the appraiser.  It is also not a professional approach to a valuation problem.Charge for your time.  If they don't want to pay then they are not my client, nor yours. Provide a reasonable time frame and  do not compromise your research and quality for artificial time frames and low fees. Provide reports that reflect your personal inspection, insights and opinion and remember an appraised value is an "opinion" of value.  It is not carved in stone.  No opinion can ever be wrong if it is based on solid research and reflection.hud@bobhud.com 

Amen! I do a number of reviews for local lenders as part of my practice. I see so many appraisers that do not write in complete sentences, do not use (or attempt to use) correct grammar, or spell check reports and e-mails. Then, they get very frustrated when the lender questions them about a report full of spelling, grammar, and math errors. In addition, reports with commentary that makes no sense to the reader or is left over boilerplate about another property. Once you send a report, you cannot get it back and you never get is back. If you so badly want to be treated like a professional appraiser in the business by clients and the public, please start acting like one. Signed, Saddened SRA.

The last paragraph sums up the overall problem. Appraising and teaching for over 30 years, the lack of professional appraisal education coupled with unethical and lazy individuals provides the scenario for the 'experienced' lender to 'train' the appraiser. Unfortunately, the professional, educated appraiser does not have the time to train every reviewer/staff appraiser/lender in the appraisal process and most actually don't care- they want the value-an appraisal that fits their template- process their loan- pick up their fee/pay. All parties must be professional- ALL!

Good article.If the $7.50 an hour "reviewer" is reviewing the work then they better know what a well and septic are, they better understand FHA rules and regs and they should know what USPAP stands for.It's not an appraisers job to correct the reviewer and explain what it all means.The days of a real Underwriter who understands these things are gone.The per hour  "reviewer" is a pain and does work off a list and does look for any red flag available, they must justify their existence and fee.To bad they are looking for grammar errors and not real  appraisal issues.When they send the report back because they gave you the wrong "Lenders zip code" or need you to explain what "rural" is,well my babysitting fees kick in and my prices go up for lost time.  

Perhaps it's because I haven't yet had enough coffee, but, as I read this thread, I can't help but think we are singing the same song, but the 1,254th verse.  Tony's article is spot on -- great insight and well written.  The replies are also great.  But.....at what point do we stop talking and start acting?Better go grab another cup of coffee !Tracy Martin  

Prior to becominng an appraiser, 27 yrs. ago, I was a computer analyst. The UAD, most of the revision request, using less compatible comparables to meet lender specific guidelines etc... are all efforts of the banks and AMC's to increase productivity through automation. This allows the lenders to use less manhours and when a unique property comes along, the man hours they pay for are minimum wage because they are following  boilerplate review guidelines. In the end, appraisers and most importantly, property owners get screwed! I recently got a memo from a major AMC stating that appraisers were not adequately analyzing current market activity and as a result, realtors were complaining that values were not coming in at the sales price. It's the restricting guidelines of the lenders/AMC's that is causing this problem. Their goal is for appraisers to submit data that fits computer parameters, not accurately value the property! 

I have sat on both sides of the table - as a fee appraiser and a bank reviewer. Honestly, I can say that the next perfect report I write will be my first. Perfection is not the goal, excellance is. That said, many appraisers view the review function as being their "quality control" department. So both sides are suspect. Sharing the common goal of providing professional services to a client that may or may not be appraisal liteate is paramount. Spell check-yes, math check-yes, signitures-yes...all simple for review internally by the appraiser. It is not that the reviewers want to check these but if is these simple issues are ignored, it raises the question as to how much more was missed in the actual analysis, so they dig. I believe that all appraisers should be required to have review experience so that they can have first hand experience of reading the good the bad and the ugly.

Your article has hit the nail on the head for me!  This has been a big discussion in my appraisal office for quite some time now...the constant revision requests for in-material items that have nothing to do with the support or credibility of an appraisal report.  I'm glad to hear that we are not the only ones with this viewpoint.  Thanks so much for your article!

The lenders, and their agents the AMCs, have done an excellent job of filter out competent appraisers.  Now these lenders and AMC want to complain about the credibility they are receiving.  Sorry, but after weeding out the competent and beating up those less competent with low fees, fanst turn time and inane stips, you can not now complain it's time for appraisers to step-it-up.  There are plenty of honest competent appraisers out there - you just aren't going to find them interested in doing lender/AMC work as it currently exists.

when the LOE states, start your  this or other comment..........." Appraiser....did such...and so on." .. honestly if i  just think that might be a somewhat clearer rendition of what i was reporting..... NO WAY...NO HOW... will i be dictated to by a client. MY report is MY work product!HVCC, Dodd-Frank or any other so called 'guideline' is blatant bs....  some bank employee, on the job 6 months, who 'took a class' is dictating what goes into what is in my report!......  and ultimately the liability of my certification... whose responsibility?Anyone out there who actually blew the whistle on this nonsense?

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