A Blueprint for Appraisal Reform

Wednesday, January 2, 2013

A brief lesson in the history of World War II will point to a success story in the rebuilding of of Europe during the four year post war period. The goals of the United States were to modernize industrial Europe, rebuild a region devastated by war, remove trade barriers, and make Europe prosperous again.

First, there was a plan. Second, General Marshall executed that plan by engaging the right people to do the right job. He had a plan to remove scores of officers he considered deadweight. He demanded accountability. Without that two- pronged approach—right plan, right people the Marshall Plan could never have been the success it was.

We are in the midst of a post mortgage crisis period without a plan and without any clear leadership.  I have had the privilege to work with the National Association of Homebuilders over the past twelve months as a consultant.  You might think NAHB would be an unlikely ally in the battle to reform the appraisal profession. Not so. They recognize that at the very core of the housing market is a collateral valuation process that is broken.

This past summer NAHB formed an Appraisal Work Group comprised of their senior leadership and members from the Collateral Risk Network. After several meetings we developed a plan, "Blueprint for Appraisal Reform" that is still in draft form. Soon NAHB will be reaching out to other stakeholders to garner broad industry support. Then the hard work will begin to execute that plan.

In the interim what can industry leadership do within their respective institutions? Do as General Marshal did- engage the right people for the right job to do the right thing. Some lenders have adopted the strategy to outsource all things valuation. There is nothing wrong with that strategy. But lenders cannot outsource their policy, risk, liability and accountability.

So while waiting for a master plan, create one of your own. The appraisal process begins with the engagement of the right people. Know your vendors. Have the right processes and policies in place to remove any bad actors. Don't be shy about it. Be assertive and fair.

There seems to be a general hue and cry from appraisers that "a few bad apples have spoiled the whole bunch". State regulators are reluctant to destroy one's ability to earn a living. That is most unfortunate. Their role is to protect the public. They are not an appraiser advocacy group. When regulators don't perform their function the entire system breaks down. Allowing unethical or incompetent appraisers to continue to operate is grossly unfair to those professionals who routinely do the right thing.

But don't rely on the state regulators to do your job. An appraisal license is a minimum standard. It doesn't constitute due diligence. A current license does not imply or infer competence for the specific property type, geographic competence or ethics. Your vendor manager should be pulling background checks, ensuring current E&O policies are in place, requiring competency exams, verification of identity, reviewing sample appraisals and checking each appraiser's disciplinary record. The engagement of a qualified appraiser has tremendous payoffs and tragic consequences if you don't follow that simple plan. Having proper fee panel management processes, practices and procedures in place will when the market returns will allow your institution to thrive.

Good appraisers need recognition and fair pay for their services. The fire that is not quite in your living room yet is that there is a shortage of solid professionals to lead us into the next cycle. The appraiser population is graying. Identify your best appraisers and create a battle plan to allow them to train and mentor the next generation. It's reparations time.

Comments

We are in a business where the people making the rules and building the forms are clueless. Take USPAP.  It should be short and sweet.  Report what you see, be fair, don't lie.  That's it.  Think of the trees that could be saved!  But what we have is unreadable and like 400 pages.  Really, is this the best they come up with after all of these years?  And we have to take hours and hours of trying to read this every couple of years.Then lets look at the UAD format.  Underwriters want comments on everything but the new format actually cuts down out comments.  Like the cost approach line where you list other improvements...20 characters.  I'm working on one where there is an in ground pool, multiple decks, porches, shed and 3 fireplaces.  How in the heck am I supposed to cram that into 20 spaces?!?"I have met the enemy, and he is us" was a joke in an old cartoon.  We allowed AMC to determine what our fees are when that could have been stopped in a month.  Just imagine what would happen if NOBODY took those $135-150 orders. I can't in good faith recommend anyone get in this business, and that's a shame.  But who wants to work in a job where your cost to operate have doubled but fees are declining?

When I got into the appraisal business, my mentor told me to follow the Golden Rule.  That has been my work ethic during the past 20+ years.  You have basically stated that as well - "report what you see, be fair, don't lie".  AMEN to your comments!

I agree with you in part, however, everybody is always pointing the finger at the appraiser when a large portion of the blame lies directly with the real estate industry as a whole.  Looking at the over all process that takes place when an appraiser is needed it envolves lots of people.  Yes there are times when I would agree that the appraiser is incompetent, not only through regional compentency but also just plain incompetent.   I review appraisals that make me wonder how some of these people continue to get hired.I've been working in this industry for almost 11 years and it has been a learning curve for the entire time.  It is an industry that is constantly changing and not always for the better. Uniform Appraisal Data Set made some changes for the better but fell way short of the mark for the appraiser to place value where it is needed and to take it away where it's not.Nine out of ten times when I see posts like yours the writer is putting the blame on the appraiser.  What about the other humpteen people who are putting the transaction together?Appraisers like me are paying out thousands of dollars a year for E & O insurance, appraisal software fees, MLS fees and dues, Continuing Education fees, and then fees to upload or download an appraisal from every Tom, Dick, and Harry who wants to make a buck off the appraiser. Maybe you should be asking the question; why does a state license an appraiser to appraise anywhere in the state when they are only competent to within 35 miles of where they live?  Why can't the so called "Appraiser friendly AMCs get their act together? When I get a call to do an appraisal they ask me two questions; what is your fee and your turn around time?  They never say, "Are you competent in this area"?  They never ask me for references.  They only want the fastest turn time and the lowest fee.  Is the appraiser responsible for this?Shouldn't this be a topic of a conversation?  Are we afraid to point the finger at the real problem?I think it's time to stop blaming the appraiser and start asking some questions about whos really to blame for this whole mess. 

When someone (see post above) so accurately identifies the simple essence of such an apparently complex problem, it bears repeating: "When I get a call to do an appraisal they ask me two questions; what is your fee and your turn around time?  They never say, "Are you competent in this area"?  They never ask me for references.  They only want the fastest turn time and the lowest fee." That is the starting point for fixing the mess...

I agree that appraisers' should be fully vetted before being added to a panel but background checks should not be included on the list of qualifications.  Appraisers generally have to meet certain qualifications which generally include credit checks and criminal background checks to be licensed. This should be sufficient to do residential appraisals. If the state says you are licensed then it's up to the lender to ensure that the appraisers' level of competence meets their criteria which should be through the review of past appraisals.

First of all one needs to start at the grass roots. Better data, which means better data collection, which means better eduction standards and supervision of Realtors, MLS, and other data collection sources, and weed out the bad ones.They need to stop the mass recruitment money spinner of Brokers, and set limits to supervision, the same as they did for Appraiser Supervisor. One broker cannot watch 10 sales people let alone, 30 - 40. More accountability, especially if they are being allowed to do evaluations since Dodd Frank. Untrained people doing evaluations, is the grass roots of the start of an improvement plan. The none college based entry level for both real estate professions, is a recipe for disaster, I agree, the right people, with the right qualification, and the right supervision, is the answer. The entry level for real estate is too low, the supervision none existent, the data collection at both county and MLS level too lose. How can we hope to get accuracy, using a hammer with a lose head.Thanks

Simple truth.....someone needed blamed. They always choose the appraiser. We were blamed for the S & L failures in the 1980s. Train wrecks get blamed on someone, disasters get blamed on someone, wars get blamed on someone. There is nothing wrong with our industry! The fundamentals haven't changed. The methodology hasn't changed. I think we still use comps....don't we?  

The only reform that the builders want is a rubber stamp. I can't wait for the "Master Plan"............I'll submit to a background check when I can get one from the builder, the loan officer and the homeowner. Along with the principles of the AMC's and their staff. And 3 references each. With credit reports. One has to know for whom one is working after all.Of course this would include mandatory minimum education requirements and documentation for the phone monkey flunkies and amc "reviewers". 

IF YOU LEAVE IT UP TO BUILDERS AND AMCs THEY WOULD ALLOW ANYBODY TO BECOME A APPRAISER LONG AS THEY GET THE DEAL CLOSED AND THE CHEAPEST APPRAISER.  LET'S BE HONEST APPRAISERS,  AMCs WANT AS MANY APPRAISERS IN THE INDUSTRY LESS REGULATION TO GET MORE APPRAISERS IN THE INDUSTRY AND THE "CHEAPEST APPRAISER"  THEY KNOW LESS APPRAISERS PRICE WILL GO UP ON THEM LESS PROFIT FOR AMCs...... GO ON TO ASC.GOV AND GET A COPY OF THE NUMBER OF APPRAISERS IN YOUR STATE AND CHECK IT ON A MONTHLY BASIS.  IN GEORGIA THE NUMBERS HAVE DECREASED BY 200 OVER THE LAST YEAR AND APPRAISER PRICES HAVE RISEN "SUPPLY AND DEMAND"!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

I have been appraising since 1982.  Some Observations:

  • Licensing in our market weeded out no one.  The worst appraisers now have credentials and get paid the same as I do. 
  • Flawed appraisal licensing enforcement.   Need layered system based on severity of violation.  Many violations should not be displayed on the license look-up.  I have seen and heard of too many good appraisers being damaged by this pathetic system.  Or stop licencing, which is the far better choice.
  • Layers and layers of new rules are being piled on appraisers, most of which have no impact on the quality of the value conclusion.  Appraisal descision makers have adopted the big goverment concept of complexity, which is very destructive in the long run.  They wrongly assume that this helps project "professionalism."  It obviously didn't work.  In spite of the existence of licensing and several appraisal organizations, we were largely blamed for the recent real estate market fall.  And now many want to add more layers of complexity.  Maybe, just maybe doing less is better, but I am afraid we do not have leaders with the guts to try that.   

 My hope is that appraising can find its way to a common sense, reality based mind set (not likely).  Maybe a new professional organization can be developed like "Practical Appraisers." Motto - Simply: Real People, Real World, Real Values.     

This is exactly the kind of thinking we need. Unfortunately, it is also the kind of regulation-analysis that is in short supply in our profession.

We are being trained for data gathering and zero tolerance form filling.  Little has been done to increase the accuracy of the value estimate.  We are risk managers.  We need to manage risk rather than fill out forms and comply with an ever increasing set of laws and mandates.  Does a mandated statement regarding exposure time versus marketing time really increase the accuracy of the value estimate?  Can anyone tell me why there are no published articles on obtaing an accurate GLA adjuster for the sales comparison grid?  Industry emphasis is way off track.    Dale Leitzke 

I have been appraising for over 30 years.  The only way to solve the underlying problems in the Appraisal industry is to do what the VA is currently doing and FHA did prior to the Direct Endorsement program.  That is to have each of the organizations, FNMA, FREDDIE MAC, VA, FHA to have an approved panel of Appraisers that are randomly assigned the appraisal assignments.  You do not need Appraisal Management Companies as a third party to the Appraisal process.  Each of the organizations, FNMA, etc establishes their own set of guidelines and Appraiser rules.  When the Appraiser is incompentant, they should remove them from the panel.  This would eliminate the undue influence that continues to be rampant in our industry.  The appraisal management companies generally are more concerned with the dollars that they can skim during the process than they are about the quality of the Appraiser's work.  While there may be a few Appraisal Management Companies that try to do it right, by an large my experience is they are looking for the lowest fee and fastest turnaround.  They want the Appraiser to agree to outragious terms that limit the Appraisal Management Companies Liability at the expense of the Appraiser.  That is why I fired all of the Appraisal Management Companies that I received work from two years ago.  Without an independant panel randomly assigning appraisals, the lenders should go back to having an appraisal department with a Chinese Wall between them and the loan officers and processors so as to prevent the problems with undue influence.  Then they can get back to the local markets with local appraisers that can be vetted for competancy.  Then maybe just maybe, without another layer of stupid management in the way then fees can provide a living way for individuals still left in this industry.  Then the Appraiser does not have to worry about being micro-managed by an appraisal management company that has little to no knowledge about USPAP guidelines.  

Hello Joan,The lenders have left us. Years ago an exec. at the old Norwest Mortgage told me that the day was coming soon when the loan officer could do it all from just his desk. Buy/sell the property, do the valuation and do all of the loan process without any of the industry leeechs such as realtors, loan brokers and appraisers (his term not mine) slowing down or interfering with the process. That is when I started to move away from the lending industry.

There are lots of quality appraisers that are also good business people. Many, like myself, spent years building up a business and good reputation where you were sought out for your quality appraisal work. That reputation you built up over years disappeared the day AMC's came into play. Its time to leave the appraisal business to the newbys and fools to scrap over the lowball offerings from the AMC's. And then, to have to put up with the phone monkeys, incompetent check sheet reviewers, long hours and high liability with no light at the end of the tunnel, the best blue print for appraisal reform for the individual appraiser is to leave the industry and go to another industry where your quality work and your reputation is appreciated and properly compensated. After 22 years, I am working my exit strategy as we speak.     

In the beginning of Dec. I was offered a position with a company at a fair base salary and very good benefits (ie: insurance) outside of the real estate world.  I started this appraisal journey in the mid 80s out of college and started my company in 1988, and specialized it in the 90s to just residential appraisals.  I have enjoyed the customers.  95% of the people that I have come into their homes are very nice and very interesting from all walks of life.  There are a few that are not that great, but that is few and far between.  But the ability to make a decent living in this field has become increasingly difficult and the expenses (ie:insurance, taxes, etc.) are over the top.  I will keep my finger in this, but the goal will be to get to a place that it will fade away.  I wonder if any of my clients will notice.  I suppose the local ones will notice by the fact that there will be an article in the paper, but the AMCs I doubt will even care to ask why the drop in volume.  The work will be assigned to someone and life goes on and there are plenty of appraisers around to pick up the scraps.  Its not that much.  And the ironic part is December was the best December in invoicing since 2004 and possibly ever in terms of Decembers back to the 80s and was by far the best month in invoicing for 2012.  I would hope that would bode well for the upcoming year, but I doubt it.  My expectation is that 2013 will be more of the same.  Be that as it may, I go out on a good note.  I tend to be one who thinks that the appraisers are pretty good the way we are.  Everybody can get better, but all you have to do is look at the UAD form and know that appraisers are not in charge of the asylum.  We are the whipping boy of the industry with very little representation when you consider the Realtors and the lenders, who have pacs and lobbyist.  Great example: I did an appraisal in November and got a request in December to do a final inspection on the property.  Only problem, I did the appraisal "as is".  Once I got the lender to tell me what this final was for, I knew what would come next.  An upset homeowner who of course was told, "well, the appraiser said you need to fix the dryrot around your window and made the loan subject to that repair."  And of course, she was upset with me.  And my response was, well, it needed to be repaired and it's good that you at least have it out of the way, but rest assured, I wasn't the one who made it "subject to".  And that's it in a nutshell.  The lenders and real estate agents (in this case there wasn't one, but you know what I mean), don't want to take any responsiblity with the public (by the way, builders can be included in this...I find it rather odd that the suggestion is there that a builder wants an acceptable appraisal even if its less than their cost...I digress).  Its always the appraiser's fault.  If they are late with the documents for closing, well the appraiser got the appraisal back late (even if they got it back three weeks ago and did nothing with it....and then wanted an extra comp and commentary).   From my discussions with my fellow appraisers, we are in agreement that this used to be fun and we felt good about being part of the process.  It wasn't always easy, but now, the fun is lost.  It's a battle.  With a lack of REAL communication between the appraiser and the underwriters.  Good luck!  I hope we can find a way out of this mess.  If we do, it will be because of the appraisers, not the lenders, agents, and/or bureaucrats!  EdG

Stop pointing the finger at the appraiser. The appraiser is being bombarded from all directions with entities that somehow infiltrated our line of work. Somehow word got out that the appraiser is the one we need to blame, go after, attack, take money away from and what ever else we can come up with, let's get em!  Years ago there was an appraisal industry that was fair, something that the appraiser took pride in and was encourage to explore and figure out newer concepts and processing of a conclusive value to a subject property.  We use to plan ahead with our lives. Now we live day to day. There are ghastly amounts of companies, government and state entities, refulators, senators, amc's, and whomever else you can name or think of coming into our small pocket of living.  What is happening is evitable. We are slowly deterioting our profession to just a stump. No more than that. So just stop coming after the appraiser. Please stop all this non sense. Some of us now can't afford to begin to go a different direction or take on a  new career change. Some of us need our jobs!

any appraiser who accepts residential work today is a complete fool.  I would gladly dig graves or pick up trash for a living before going back into that extorted profession.  

I was asked for a "professional reconsideration of the value" last month? Yes, a twenty-something at an AMC, hired from Craigslist at $8.00/hr. If you want to end this AMC charade, demand to talk their appraiser (they are suppose to have one). If appraisers quit responding to calls from someone to doesn't pocess an appraisal license, then you get what you deserve.

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