"Low Bid" Appraisal Ordering Yields Quality Work (Most of the time)

Sunday, December 8, 2013

Post No. 34 – Some of you may have seen a recent article by Isaac Peck, Associate Editor of WorkingRE. His article was titled "'Low Bid' Appraisal Ordering and Its Effect on Quality." It can be found at this link - http://www.workingre.com/low-bid-appraisal-ordering-effect-quality/

This was a well written article and obviously presented some factual situations. However, as a review appraiser for almost 22 years, I feel obliged to present the other side of the coin. I have overseen the order and review of about 15,000 appraisal reports over the years. Whether I was an employee of a bank or acting as their Agent, I was/am essentially an AMC. We do the same thing whether we are employees or hired companies/contractors.

Some facts based on what I have seen over the past two decades:

1. Around 90% of appraisal assignments are awarded to the low bidder.
2. The vast majority of assignments, whether awarded to the low bidder or not, are acceptable.

Therefore, awarding to the low bidder should not adversely affect the quality of appraisals over the long run.

All of the good appraisers out there need to realize that almost every assignment they have won is because they were the low bidder! I doubt they would say their work product was inferior for all of those assignments.

Let me provide some actual numbers from the past few months of awarding assignments in a specific market for a specific client. Amazingly, all of these appraisals have been reviewed and accepted without any significant revisions. All of them were awarded to the low bidders.

In October, we awarded 31 appraisals with fees totaling $77,600. If we had the philosophy that all low bids would result in poor quality appraisals and we went with the second lowest bids (who is to say all of them would result in better products?), the fees would have totaled $99,900! What kind of service would we be providing to our client (or employer) if we had them (or really the borrowers) pay $22,300 more for these appraisals that had no assurance of being any better than the low bid reports? That would be the kind of service that would drive you out of business (or be fired, if an employee).

I once told an appraiser that we were concerned about engaging him because his fees were so much lower than others in the market. He retorted, quite strongly, as to what right I had to opine to how much money he thought his time was worth! Also, he said there are a lot of bad $5000 appraisal reports out there. You get what you pay for certainly doesn't hold true in the appraisal arena.

While there is a lot of concern about AMCs saving $50 and getting a poor report that might be off by $50,000 on a house appraisal, this pales in comparison to the errors on the high end. We once had to lower a $500 Million appraisal to $400 Million. All because the fee was $50,000 didn't mean the report was good. How many erroneous residential appraisals are needed to get to this $100 Million error for one assignment?

KC Conway, CRE, published a report a few years ago that showed that appraisals on average were in error by about 20% (my personal data over the years shows an average of 22%-23%, albeit my data isn't a scientific study like Mr. Conway's). These appraisals probably had fees ranging from around $5,000 to $50,000. There is no guaranty of quality as fees go higher.

One common question I have been asked over the years was why do we go with low bids? There is a logic to this. If we have grouped a set of appraisers that we know are equal in competency, then the major decision maker becomes fee (and time in some situations). As with the 31 appraisals I mentioned above. We know all of the appraisers in this market. We know which appraisers are say Level A or Level B (we don't go down to the Level C or lower quality appraisers). So when we have them bid we know the competency is about equal and the likelihood of approving their reports is very high. Where is the logic in not going with the low bid?

There will always be those situations like Mr. Peck encountered. Every industry probably has something similar. But, what about the 60% or 70% or 80% or 90% of all appraisals that are done right, and selected because they were the low bid. Not enough stories are written about those.

Ban The Sales Comparison Approach!
George R. Mann, CRE, FRICS, MAI
"The postings on this site are my own and do not necessarily reflect the views of Situs."

Comments

This article must be referring to the authors experience with commercial appraisals, since the average price for his most recent appraisals in $2,500!! This is a different world from the typical residential appraisal, and I'm not sure the comparison is very valid. There's alot more competition in residential, and larger differences in qualifications and experience.

I find that many reviewers are given a template and if they match the template then they pass. The reviewer has no idea that the comparables are all wrong, the appraiser never even drove the comparables, and that their adjustments maybe wrong for the market. I have seen all the above more than once and as many appraiser have. You have to be a seasoned appraiser to do a proper review - not a commercial appraisal - or lack any real field work. There are many appraiser that do no even know how to develop market adjustments or even what the term paired sales means. I reviewed one appraisal where the appraiser used all MLS pictures, one in gated community (not the subject). When asked why he used a gated community with no explanation, the response was I was only paid $180 and I could use what ever comparables I wanted. What was really weird is that this MAJOR AMC had no problem with this even when all the errors were pointed out. This practice seems to becoming the norm for these low paid appraisers. Residential appraising and commercial appraising are two different worlds and are really very different in how you calculate your adjustments, looking at comparables, and looking at the correct segment of the market. In addition, today's underwriters have no training in appraisals but rely on a check list. If it matches it passes. We don't need checkers - we need real seasoned appraisers to do reviews and to do appraisals.

I'm sorry, your article did not convince me at all...and your last comment of Ban the Sale Approach is about as stupid as I've read in a long time... glad I'm leaving this business.... people like you are a reason why this business now sucks and has no credibility.

The article is obviously geared toward commercial appraisals. In the residential world, we get the blasts for orders, and even when we think we've provided a reasonably priced bid, it goes to someone else. What happens is that these low, low bids become the new normal for the AMC, and when we submit our customary and reasonable fee for the order, it's rejected. I have heard appraisers who sometimes win these bidding wars say that if the AMC wants to pay $175 for a residential appraisal, then they'll get a $175 job. So yes, I think the low bidder is sometimes performing below their capacity in these orders. That hurts everyone in the industry, not just the person that took the low priced assignment. Where is the CFPB fee tables promised so long ago?

George here....reading your comments. Yes, the data presented, and my 22 years of review experience, are based on about 90% commercial and 10% residential appraisals. So, the data and opinions hold true for both commercial and residential. But, again, the key is I get to select the list of approved appraisers. That right there is 95% of the problem being solved. As I state in the blog, if I am bidding to a group of equally qualified good appraisers, then going with low bid will not result in lower quality. It is the AMCs who don't know, or can't tell, the difference in quality and have Level C low fee appraisers bidding against Level A and B higher fee appraisers that cause the problems. This exists in commercial as well as residential. One point being that there are good and bad clients, good and bad AMCs, etc. But, not all AMCs are bad. Not all clients are bad.

As for my 'Ban the Sales Comparison Approach' signature, here are a few facts for the American appraisal industry that is hooked on comparable sales like a bad habit:

1. Mortgage Lending Value in Germany has been estimated in appraisals for 100+ years using only the Cost and Income Approaches.
2. In 100+ years, NO (!!!) loan based on MLV has ever defaulted (yes that is a perfect record for over a century....two loans have gone bad overseas - one in America and one in Greece).

From the above a few facts - 1) You can appraise without sales comps, and 2) Maybe lending based on MLV would save the American taxpayers billions, if not trillions, of dollars from the cyclical loan losses incurred by our banks.

OK George... you lost me. First, how can you say that your review experience (& data)is based on only 10% residential and then make the leap that same 10% is representative of all appraisers/appraisals?

As far as mortgages in Germany...what does that have to do with anything? No loan in Germany has ever defaulted but two? Where do you get your information (or data)??? Or put another way...what kool aid have you been drinking? You didn't mention that they have shorter-term loans and probably lower LTV's than in the states.

Here is some recent information about Germany:

Housing prices in several cities in Germany could be overvalued by as much as 20 percent, according to the country's central bank.

In its monthly report released Monday, the Bundesbank warned that price rises in urban areas "are difficult to justify based on fundamental factors", although there are no signs of substantial exaggerations in the German housing market in general.

"Over the past three years, the prices for houses and apartments have risen by a total of 8.25 percent. This is due to a 'marked gap between property prices in urban and rural areas'," the bank said in its press release.

The statement added that in Germany's largest cities, apartment prices had risen by more than one-quarter during this period, an increase that could "give rise to fears of a broad-based property price boom".

Urban housing markets could be up to 10 percent higher than acceptable, it said, adding that in attractive large cities, like Berlin, Hamburg, Munich, Cologne, Frankfurt am Main, Stuttgart and Düsseldorf the overvaluation could be as much as 20 percent.

Stronger demand for property than was expected during an economic recovery is seen a reason behind the price hikes, according to the Bundesbank, adding that the German property market became more attractive to international investors after the property market price bubble in the U.S. and in a number of European housing markets burst.

"Furthermore, the appeal of property investment has grown given the lower returns on financial assets in recent years," it said. It also earned that any price corrections in the housing market could give rise to notable wealth losses for households.

However, the Bundesbank believes that it is very unlikely that this will result in macroeconomic risks to financial stability. The conditions placed on mortgages are much tougher than in the U.S. and other parts of Europe, including shorter-term loans. This means that banks and other lenders would probably not be severely affected.

Thanks for the information re Germany. It helps support two of my major contentions:

1. Prices are not reflections of value. That whole article clearly shows that value is 'fundamental' (intrinsic is another common term) and prices can depart from the underlying fundamentals. That is exactly why I say ban the sales comparison approach. I'll need to keep this article handy!

2. The article also explains that the German lending is more conservative than the USA. In fact, in the Mortgage Lending Value (MLV) arena (which is not the only way of lending...maybe not even the major way of lending) loans at 60% of MLV max. Maybe 50% in many cases. So, if prices in Germany fall 20%, let's make it 40%, there will still very few, if any, defaults. A $500,000 loan on a $1,000,000 house is still in good shape when the value declines to $600,000.

The way I think lending should be done in the USA (as if anyone cares what I think about this!) is we should have aggressive LTVs against MLV. But, if Market Value (our definition in the USA which is really Market Price) is above MLV, then the loan against that amount should be VERY limited, if allowed at all.

So, for example, back in our bubble when a house was priced at $1,000,000 when it's true value was say $500,000 (very typical for the sand states), we would allow a 80% or maybe 90% loan against the $500,000 MLV. This loan should be VERY safe. Then if the bank or borrower wants any money against the high risk price of $1,000,000, the interest rate should be extremely high and the loan amount very low. In the past, or even now really, we would lend $800,000 or $900,000 or even a $1MM or more on this house. Obviously, huge losses have to occur.

As to the lack of loan losses in Germany (using MLV), either the HypZert organization mentioned that in the classes I took or it might be in their materials. They have no reason to lie. They simply explain the process of appraising MLV and dictate what it takes to get their designation, etc. I like to be able to prove everything I ever say, but right now I don't have this particular quote handy and can't recall if I heard it from an instructor in Germany or read it in all of the materials I had to review to get their designation.

Like the others, thanks for the discussion. And do continue to challenge anything I, or anyone, ever says. I know I commonly ask to see it in writing, else I am not sure I believe it.

It sounds like you are making a case to change the way lending is done in this country( vs. Germany) rather than changing the way appraisals are performed (cost & income approaches vs market). I couldn't agree more. Lending has become more about casino night than prudent lending practice. I still think that the market approach(even after your lending changes) is the best approach to value.

Markets go up and markets go down. I don't think you can even out the graph by restrictions, regulations, and the like. What you can do is require larger down payments (at the expense of fewer transactions) or higher credit standards for borrowers. I digress. Let's get back to appraisers.

The fees generally being offered today are the same or lower than the fees I was collecting in 1998. Is that happening in commercial? I don't know. I couldn't tell you because most of my work is 90% residential. Nobody in their right mind would enter this so-called profession (after meeting all of the educational requirements) for these paltry fees. The average age of a residential appraiser is over fifty and getting older, not younger. What your 10% residential review/appraisal experience does, George, is prevent you from entering the trenches and see what life is really like as an appraiser these days. Just like the Institute, your have abandoned us and don't really represent us or our interests. You would rather use data points and graphs than true market data.

Regarding commercial fees they have declined ever since I started in the industry in 1986. We used to get no less than $10,000 for a basic hotel appraisal (think Hampton Inn) in the late 1980s. By the mid-1990s I could get these for $4000 and to this day I still can. The average appraisal fee I have experienced (mainly Mid-Atlantic and Southeast) has been around $3000 from say 1990 to 2010. The larger banks dealing with larger properties usually had appraisal fees average around $4000-$4500. I was talking with someone this week who said the average appraisal fee in Florida was down to $1700. I have found Florida fees to be above average in general, just for some perspective. That is a scary drop. ((Basic Note: The numbers used here are averages and do not reflect a specific property...fees vary by location, report type, and many other factors.))
I agree, I do think lending will change. But, I do want us to totally start over re our appraisal industry. For 80 years, we have simply followed prices up and down. We provide Market Price reports (or Price Confirmation Reports as some call them), not Market Value reports. Prices go up and down significantly, but value changes very slowly over time (under normal conditions - 9/11, Katrina, et al can cause sudden and significant changes to value). I always go back to the stock market. The value of IBM barely changes over time. However, the price can be $150 or $200 in the same year. Except for Warren Buffet, the typical shareholder only purchases shares in a company - they do not actually purchase the company. Prices are simply a reflection of the optimism, or lack thereof, that the stock can be sold at a higher price in the future. That was what was going on with house prices in this last bubble - people thought they could pay a record price today because they could sell to another sucker at a higher record price in 6 months. As my idol Joseph Granville (RIP as he passed away a few months ago) said many decades ago, you need a bunch of 'bagholders' at the top of a market to take on the losses as the market turns down and back to its fundamental value. Sadly, a lot of 'normal' people were the bagholders. Some investors were also and they deserve such as they play the game like it is a casino.
Not sure what to say about not representing appraisers. That's certainly not my job and I doubt anyone would want me to do such. I have never run for any office in any of the national organizations. It is not important to me anyway. It is people like Joan Trice, and others, who are taking concrete steps to change the industry, change how appraising is done, change how lending is done, etc., that most interest me. Complaining about AMCs or licensing from 1990 is not worth my time. Changing the future is.

I forgot to comment on the percentage of appraisals I have reviewed.

Obviously, no one has ever seen every appraisal in the country. But, that doesn't mean assumptions and generalizations cannot be made from what one has seen. I have been lucky enough to review appraisal reports in all of the states, except Alaska (do they appraise or lend up there? :) ). Also, I have reviewed in foreign countries.
I have the seen work of a lot of appraisers all around the country. From work done for small community banks to the trillion dollar banks and CMBS/Capital Markets firms. Also, eminent domain and tax assessment appraisal reports. My portion of residential reviews is small in comparison to commercial reviews. But, if the patterns I see are the same across the nation and over the past 20+ years, it is pretty easy to conclude this is the norm nationwide. When you talk with hundreds of other review appraisers and hear the exact same comments that you encounter it solidifies that what you are seeing is the norm nationwide. My opinions (based on my national and international experience) about appraisal quality, appraisal delinquency, or whatever are not unique. I am not the first to even state such concerns. I am just one of many. Maybe a bit more vocal (albeit I have laryngitis so thanks to email and such I can still 'talk') than other reviewers - and many of my writings are from other reviewers who wish not to speak in the open (many banks won't allow their employees to speak in the open about such issues).
Anyone who has ever attended one of my review seminars knows I preach two terms - Communication and Teamwork. My goal is to have fee and review appraisers work together and not against each other. Also, to help fee appraisers improve their work product so they can work for the better clients who actually do care about what the appraiser has to say.

I agree with much of what you're saying George and a respecting fan. I also know that, even when data is perfect, there are great limitations to appraisal accuracy. However, I am interested to see the study that you refer to. I do quite a few appraisals for residential pre listings and relocations and if my value was in error an average of 20%, I would not be too popular with these clients who have a unique ability to track my success. Can you provide a citation for the study that you're referring to? If it is the CRE Finance World Winter of 2012, that study measures the appraised value of commercial properties with gross proceeds of after liquidation and not the actual accuracy of the appraisal. Here we have a definition of value issue. Maybe you can clarify for me. http://www.AQualityAppraisal.com

Yes, that is the study. Here is the link for others who have not seen the NY Times article about it - http://www.nytimes.com/2012/05/09/realestate/commercial/appraisals-overv...
As I did not perform the study, I certainly do not know how they compared the appraised values with the sale prices. I am fairly certain they did not use foreclosed prices. I would assume they used either the price at the time of the appraisal or the price when the bank sold the property (which I contend is at market and not distressed the vast majority of the time). If the latter, then obviously the comparison would be flawed as market conditions changed. I would think any study like this would avoid such obvious 'errors.' But, I do not know for sure.
My own experience is based on being part of 60+ bank acquisitions and valuing their portfolios (property by property) and tracking that info against their appraisals. -20% was the minimum deduction we have made on a portfolio and up to -30% is the highest. Time period is over 20+ years in markets all across the country., Very consistent over-valuation. I might need to also track down a study that was done comparing market expectations versus actual returns (they used public data from NAREIT, NCREIF, etc.) - it also showed the 'market' (and these are the most experienced real estate investors in the world) overpaid by an average of 20% over the past 20+ years. The data is always consistent in this regard. Oh, and re the last study, if the market purchase is reflected in sale prices and appraisers in the USA for the most part go at the comparable sale prices then it is easy to see how appraised values would then be 20% too high.
Your relocation appraisals I have always contended are the only true appraisals done in America - well not exactly the only, but at least there is no target price to go at. And your clients do measure your accuracy - unlike general lending where the client wants you to hit the inflated sales price and is happy with you being off by 20% as it makes their deal work.
The best quote in the NY Times article is this one - “The sale price isn’t a good way to evaluate the accuracy of an appraisal,” Mr. Garber said. The problem with that is almost every appraisal in America is based on sale prices!
You made a key statement - our definition of value is really the problem. The definition instantly presents a problem when it says Market Value is .....'...price...'. Why is the word price in a definition of value? Cost, Price, and Value are three different entities. We don't define 'Fruit' as being 'A vegetable...'! It makes no sense at all to use price in the definition of value and until we change that we will not get anywhere. Thanks for the discussion. It is always good to air out all of the issues and hopefully over time changes that make sense occur.

Assuming that you are right (which I don't believe for a second) this is the ONLY instance in the U.S. where one can obtain high quality workmanship for chump change.

Believe it if you wish but those of us who live in the real world know the truth about appraisal quality today.

Most are good according to what, you're AMC checklist? Unless you are personally familiar with the market at hand you are in no position to say whether its a "good" appraisal.

Mr. Vann, my take on your claim of reviewing some 15,000 appraisals during your career, is that, perhaps you ought to try doing some appraisals. Your problem is lack of experience. The way I read your column is that you are more an advocate for the lender and a 'let's get the cheapest appraiser' kind of guy. Your report claiming that appraisals are off on average by 20-23 percent sounds about right for commercial appraisals, but please emphasize that fact. I believe your claim that 90% of "low bid" appraisals are acceptable. That doesn't mean they are credible.

This is the way that I see the cheap AMC working. In the first place if an appraiser doesn't comply with their fee, then forget about getting any work from that company. I wonder how a class action suit would turn out against a charge of priuce fixing by some of the largest AMC's in the land. It seems kind of convenient that many of them have the same pay structure and the same rules of punishment for those that don't cooperate. The independent fee appraiser is forced to accept or go out of business. Getting back to the 90% acceptable. I surmise that this is suppose to justify paying demeaning fees to appraisers. You need to get out from behind the desk and go on the road to do some appraisals and see just how much time and effort a good appraiser will put into a single report.

Among the mix of low fee appraisers on your roster, I'm sure there are a some with years of experience. The problem for you is that these are the very appraisers that know how to cut corners, in such a manner that you would never know the shortcuts they take. They know how to make the report "acceptable". You force the appraiser into this mode with degrading fees. I've been appraising for 25 years. I've seen many well experienced appraisers, bright individuals, with all kinds of credentials. The problem with some of them is that they fall flat on their face when it comes time to get out of the office and do the road work, then put the appraisal together. They're great at doing a review pointing out all the things that are wrong with someone else's report. Another part of the equation in your ,90% acceptable rate, in the meager fee you pay appraisers for reviews. Do you really think that you are getting a first class, top grade, credible desk review for $75-$90. This report becomes acceptable so that the deal gets made. It passes muster because the appraiser can't possible spend the proper time necessary to do a good quality thorough job. IMO, the whole review process is flawed. It's set up to make the deal fly while you sit there insulting appraisers with low wages. The free market is not free in the appraisal business because of attitudes like yours and the rest of the cheap AMC's. You all have the low-ball fees going your way for now but it is not going to last much longer. Appraisers are beginning to figure it out.

It's disheartening to read reports like yours. It's funny that I never hear a practicing, experienced appraiser praising the Cheap AMC's and how grateful they are to be working for minimum wages, after putting in years of training, spending thousands of dollars annually keeping up with the ever changing technologies that are suppose to make the job easier, only to find out that it's continually adding more and more time to each report. The only advocates for these insulting fees, unfortunately, are the people with the check book, AMC's. However there is change a brewing. I'm been contacted with some good AMC's that are respectful to appraisers and willing to pay reasonable fees.

I know you won't find this review to you liking. Likewise, I didn't find your article as an encouraging endorsement for the appraisal business, specially to anyone who may be interested in or considering the profession.

George...you've got be kidding me. Maybe after the next 15,000 appraisals you'll get a clue. Don't even try to justify your opinion any further. Those who can appraise, appraise. Those who can't Review' That's My opinion and I'm sticking to it!

Not that I really need to defend any staff I've had over the past 20+ years, but just to clarify...I, and every reviewer who has or does work with me, has been a fee appraiser. Also, they have all worked at banks. I never hired someone to review who had only been a fee appraiser - until you have actually worked inside a bank, you are clueless as to what goes on and what is really needed. I would challenge any appraisal department or AMC to say they have reviewers as qualified as my roster - generally, the reviewers I work with have 20-30+ years experience as real estate appraisers and reviewers. Most have more experience than the fee appraisers they are reviewing. Also, as bank staff, most have done evaluations on an ongoing basis, which is essentially appraising so they know their markets all over the country.
Funny comment about reviewers not knowing how to appraise. Per above, the reviewers I have and do work with know how to appraise better than most of their peers. And they certainly can judge what is a credible or good appraisal and what is not. After all, that has been their job over the decades. I have always told fee appraisers they need to be reviewers. Until you review you have no clue as to the quality (or lack thereof) of work that is out there. You do not have full understanding of what clients are needing from the review process - and from appraisal reports. Fee appraisers who do reviewing here and there usually tell me it is an awesome experience. They learn how other appraisers solve complex problems. See techniques they have never seen. etc.
Also, I can proudly say that over the past 5+ years, 100% of our clients have come from word of mouth - fee appraisers recommending us to banks who need assistance with their appraisal management. So, yes the good appraisers who are winning work do praise certain AMCs.
As for fees, the good appraisers we use bid what they want. They get paid their full fee. We have never taken a dollar of any appraiser's fee and never had them pay to use any bidding system. The market bids what it wants. These appraisers are getting paid more than the bad appraisers that the industry complains about. So although they are winning as low bid they are bidding much higher than their competition would probably bid. Most of these appraisers are making such a good living it has been difficult over the past 10-15 years to hire them in a bank reviewers. In fact, I've had several leave reviewing to go do fee appraisal work (yes commercial, not residential). Still appraisers could probably double their fees and the industry would have to pay for it as most appraisals are required by law. That is up to the industry to solve. Whether they do or do not solve that, users will continue to use the normal bidding process like most industries do. And appraisers will continue to set the market as to what they want to get paid. If an AMC is taking part of your fee, then you probably should not do work for them.
There are good and bad clients out there. I have had many appraisers over the years come up to me and say the best advice they ever got was from a statement I make in most classes I teach - 'You can fire a client.' Why complain about a bad AMC or client? Stop complaining and simply don't work for them. The same advice goes for reviewers. Why complain about bad appraisals? Stop getting the bad appraisals and stop using the bad appraisers. Take positive steps. Hopefully, good appraisers will find good clients, and vice versa. Those that do will certainly be enjoying their profession a lot better!

Following is a response sent directly to me from an AMC. Since I didn't ask for permission to post this, I will leave the name anonymous. It just provides a perspective worth noting.

George,
You and I have conversed via email in the past.
Your article is SPOT ON!!! The entire world commerce is driven by “competition” and the lowest fee is not the poorest appraisal work. I have seen thousands of appraisals in my career that I have had to pay a premium for and the reports was terrible. On the other side of the coin we have many long time, loyal, excellent quality appraisers that charge a little lower fee to compete for our business because they of the wonderful working relationship that we have forged. In short, price is not always associated with quality. In all fairness there are exceptions, but to your point, in many cases, just like the real estate that we value “supply and demand” may be more of a factor in the appraisal pricing dilemma than “report quality”.
It is incumbent upon those that order appraisals that we use the most competent appraisers, and it is incumbent upon EACH of the appraisers who accept the assignment, regardless of the fee, (per USPAP) to complete a compliant appraisal.
We all see this as a delicate balance, and the answer is having a professional respect to pay fair wages for good quality work, while being mindful to the consumer, who has to pay for this process. This is no different in any other profession, medical, automotive, retail, etc…….
Thank you for balancing the one sided argument for the sake of good appraisers who may choose to be competitive!
Sincerely,
((..........))

Mann's article does not apply to residential AMCs. There is a huge difference between residential and commercial appraisal lender work. I have done both. When ordering commercial appraisals for a bank you have a selected list of appraisers you know and usually have used before. When you are paying $2,500 and up you want to know who is getting the assignment. Reviews are done by appraisers, not software or unlicensed persons. Residential used to be like this before AMCs and is still like this for local direct lenders. National AMCs do not have this. It is not possible.

The gap between residential and commercial lender appraisal is widening. I recently spoke at an appraisal workshop about this topic. Commercial appraisers are considered professionals. Residential are considered all the same and definitely not professionals. I call it a chasm, disconnect, widening gap, etc. Another unintended consequence of licensing. It is very sad. I do both residential and commercial appraisals. I have always been treated as a professional. I have never worked for an AMC but have heard a lot about what other appraisers say.

Commercial fees in my area are way down from the peak in 2007 and have not come up much. Residential fees are up from the lows just after HVCC. It is not always about the money.

You get what you pay for. Low pay for a complex appraisal will get you an inferior report.
How about $1 million to $3 million plus property values on 2055 exterior appraisals for $190 to $250. Low bid appraisals for sure. Appraisers are prostituting themselves bending over forwards, sometimes accepting an assignment without even knowing anything about the property. Most of the time all they know is the property type. In a hurry to get the assignment before the next broadcast appraiser gets it, just click the button and find out later what you have accepted. When I would take the time to learn what the subject was by looking at an aerial photo, or public records to get a clue, then by the time I clicked the button to accept the order it was gone.
But the really sad thing is to see how little appraisers are willing to accept to do all the work and take all the risk. I have seen this industry go backwards further than I ever expected it to go. AMC's mostly the engines of the very institutions that got us into this mess are getting from day 1 what the Frank/Dodd bill intended, but we appraisers are still waiting on the Customary and Reasonable Fees we were also suppose to get.

I've been appraising mostly residential in Los Angeles for 25 years. I have had to stop accepting review orders due to the very low quality that I see especially in the last 5 years. The AMC's use the cheap appraiser then want someone like me to sign off on the garbage and be 100% responsible for the value-no thanks. George is just another one of those hacks that calls himself a reviewer. Reviewers now are just glorified box checkers and wouldn't know a bad appraisal if it bit him on the rear.

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Actually, I do think this can be a new myth which may parents learn bad data files. My experience are generally that parents' healthiness literacy is fabulous. But there is increasingly a good deal of misinformation near, so mothers and fathers do could be careful. pro babby
And also, of learn course, there are actually every bit of information about the reason babies poop immediately after they partake of, why barstools is exceptional electric-green sometimes those were as much as possible I learned within the practical difficulty with working for 2 decades in the most significant children's doctor's near a vicinity. vip babby
Vendor applications arrangement is a kind of financing arrangement whereby finance exists to the shoppers can use being new marketing, promoting & survive closing means. Country, show, city not to mention municipality investment is named public schooling. It might be anxious utilizing your budgeting thing to do. 1st finance hut
Each type company the particular unique manner of marketing influenced by which annuity to choose focus they've regarding company. Advertising a company is purely together with the products. Making it is a plan not to mention receiving typically the overview will not be enough. Company should certainly put it is a plan to activity and honor it up and also evaluate doing so periodically. vip finance palace
Small business enterprise finance can be described as stepping stone for all those small companies. With smallish enterprise investment consumer are able to minimize that of funds which the borrower creates during the manufacturer. There will most certainly be two main various finance reachable to smallish organization. e finance town
The fellas I'm in association with, the of us I help and the wonderful I discover their am solely out shopping would like to have a good solid tooth yanked than consider a fit, choose a good solid shirt, not to mention, for which may matter, seek sweat socks. An illustration of this this disposition is Diane p Bentler, a good solid 27-year-old financial adviser through Smith Barney, what individuals informed everybody that shopping "is absolutely torture. " "Going in stores, looking multiple factors? shopping joint
I'd sometimes assumed until it was the degree of service who Jordan, Donald Trump and also Tom Cruise vacation trip employ if you want to outfit themselves because of the busy everyday life as zillionaires. Many menswear shops provides personal service if you spend lots of money throughout their merchants. e shopping boss
But We certainly have recently seen that the exact thing is obtainable to regular those with less astronomical profits, retailphobics who would like to avoid shopping to get but in some cases don't trust their particular judgment not to mention want individual attention company logo can't get searching online. urban shopping diary
He works for ones company given the name Tom Diane, a secretly owned service founded for the duration of Nashville for the duration of 1966 no advertise not to mention relies upon word of mouth marketing to choose its over all stock. (The corporation also really does women's office attire, but a lot of its over all stock are lad. )#)#) future shopping club
Shopkick Inc., the shopping rewards moveable application popular with big-box groups, is getting started with Main Discourage. The Palo Alto, Calif. -based engineering firm are generally wooing society retailers with the aid of coffee channels to bakeries if you want to clothing dealers in 10 downtown centers, among them Chicago, in a good solid bid if you want to expand his or her's reach. free shopping bite
A shopping applications, introduced especially last September, advantages potential customers using ideas named "kicks" in support of entering a good solid store. It is akin to all your paper commitments punch card accompanied by a smart cell, but patrons aren't had to purchase anything to have points. e shopping road
Some day-to-day prayer entry could consist of: "The Scriptures lay claim that health can be described as promise and also an inheritance if you love and also serve a lot of our creator, and we tend to thanks very much for using sickness far off from our your kids, for making health for years, 1st parents
1. stopping their acute wounds, not to mention supplying these products via destruction. We pray construct y may not turn out to be depressed not to mention discouraged, that they can indeed be in a sound body, that Cannot Word takes strength thus to their bones, and that also every definitely will fit these products. " parents tutorial
We choose our your kids to decide on their colleagues wisely not to mention socialize with individuals that share his values and can not cause them to become become known to cause wrong not to mention dangerous types of conditions. We desire to enable them to be self-assured parents side
A prayer entry example may well be: "We pray which our children can be wise whereas choosing his friends. Thanks very much, God, for going for self-esteem and also confidence, that some might not obtain a step just for crowd has been doing it and they're going to certainly in no way let fellow pressure structure their judgements. parents story
in who these are definitely and to produce choices influenced by what construct y know are generally right in lieu of from insecurity or simply a need in support of acceptance. Day-to-day, we might possibly pray for ones children, his friends, and anybody in addition to require a particular influence at the lives. parents future
Within the last few ten decades, maybe some lttle tid bit longer, way more golfers for ones professional tours can be switching if you want to belly and also long putters knowning with which has led way more amateurs to vacation at suit and provides the given shafted putters making the effort. 1st sports tutor
We give consideration to very firmly which the belly and also long putters will continue to and become widely used with associate programs and idiots knowning that overwhelming tendencies amateurs is required to be testing out and about or selecting these putters sometimes. my sports captain

Bulls foundation Eddy Curry end up being feeling terrific about his future. Curry, who's travelling to be watching for concept on doesn't really matter if an turned out to be bigger heart helps keep him from signing at least one contract extendable, was regarded Monday buying completely latest Bentley concerning Bentley Silver antique Coast. But what specifically really procured Curry's big eyes was this unique blue convertible Ferrari parked prior to an upscale trader, www.cybershoppingwatch.com
Shopping spiders are working at comparison-shopping in any more potential proposition. Named 'bots' with the help of techno-speak, the on-line world websites work in which: The customer types inside of a request, that bot qualifications to completely different sites on the lookout for similar or probably matching toys. www.allshoppingfun.com
This seriously isn't your customary neighborhood researching tour. Right away, it covers an inexpensive amount something related to territory, because of this wear calm shoes. Way more important, the motivation suggestions at the event, in place of simply typically the material. Have the ability meet a large number of engaging, ingenious, unusual shopkeepers who love discussing in relation to their shoppers and have a passion for what a lot of us do -and what specifically they list. www.supershoppingtoday.com
For the lady day-after-Thanksgiving researching foray, Chicagoan Rosemary Lebron sleeps with the help of her gear, rises concerning 3 at least one. m. and is particularly on her strategy to stores a matter of minutes later. Such approaches put at least one dent inside of a Christmas heal list that can be 50 humans long: mankind Ray, the five your kids ages 3 to each, plus nieces, nephews aside from friends. www.vipshoppingboard.com
Vogue cigs have always been produced with British You and me Tobacco enterprise control in nova scotia, Russia, The world, Holland, Southern vicinity Korea aside from South Africa. Each summer, they may sell proportions of cigarettes already in the marketplace. They flaunt their cigarette smoking in around 190 parts. www.myfashionessay.com
The merging of Mexican isles American Smoking, with it happens to be American professional Rothmans Another country in 1999, a profile join enterprise added with a large number of new awesome cigarettes devices among which often and Form cigarettes. The Form brand become more refined into a form of "women’s" cigarettes throughout the world. www.1stfashionwhiz.com
These ultra-light smoking are with good deep, multi-faceted choices. When cigarettes Vogue Blanche there exists an punishment of coolness, and Form Noire – at least one warming punishment. Despite a large number of changing with the help of design this unique multifaceted flavors of Form cigarettes might be remained unchanged. www.cyberfashionpioneer.com
The You and me Cigarette Enterprise LTD carries made Form cigarettes except aided by the point who not specifically are a lot of us popular but possess a good blend. This cigarette is created primarily aided by the female families. The reputable pop diva Madonna utilised this provider as this unique title from merely undoubtedly one of her very popular songs and then the girl with the help of also cigarettes it with the help of her over the internet video multimedia. www.ultrafashionlegend.com
There are classified as the Vogue Fantastic Slims cigarettes for a woman who prefers an exceptionally slim, attractive cigarette, Vogue Fantastic Slims Menthol cigarettes for a woman who prefers menthol aside from Vogue Slims cigarettes aided by the everyday someone. Vogue smoking are attractive, super-thin aside from long. www.todayfashionhero.com
This cigarette is among the most preference on most women towards its consistent preference, high excellent and very affordable deals. Style Cigarettes’ overall look, uniqueness aside from noticeable personal taste makes brand reputable among numerous women everywhere you look. www.myfashiongenie.com
The special design at the Vogue elements symbolizes high-end, class aside from refinement. The delightful design at the pack featuring a white color with all the miniature end with leaves in different colors causes a trusting image for Vogue Cigarettes that is most certainly very popular with many something related to its women's consumers. www.thinkfashionjourney.com
The Form cigarette uses the most suitable tobaccos aside from additives that its choices relaxing. Vogue cigarettes employ a great experience of debt of fragrance and eye-catching smelling smoking. This cigarette smoking exclusively located to women of their ages. Vogue brand is famous aided by the exquisite experience of debt of pink and fragrance, the large choice of complex tones out of your tobacco vase and very good fragrance having tender aside from delicate updates. www.todayfashionnow.com

The greatest component of this cigarette smoking is it happens to be filter. The form of filtration can grant making the smoker an astonishing pleasure immediately after inhaling. It could give ideas of taste towards smoke cooker. Any partner likes this cigarette smoking from the earliest inhalation they are willing to feel this unique satisfaction. www.bestfashioncounty.com
All terrific tobacco aside from related item – even if chewing smoking, cigars, cig lighters or probably cigarettes have always been strong using traditions consultants. Although way of life reduce free of inventions, without plan to widen this unique limits something related to habits that often obscure new imagery. www.vipfashionbay.com
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A police officer can certainly ask you once you know why you were once pulled around. It is invariably perfectly acceptable to mention “no” reside can't expressly know the the police officer removed apart you around. www.lawannex.com
At very often over typically the exchange, be considerate towards the authorities specialist. Acting with the aggressive methodology can trigger want you to more likely be ticketed. Even, it could cause some authorities officer for helping respond with the help of kind. www.1stlawtutor.com
Individual may it could be you've arrested for resisting people court or may perhaps order you to definitely the covering. Treat this unique officer using kindness aside from respect and will all applicable instructions. www.freelawtrainer.com
Should the law enforcement special asks you to definitely exit typically the auto, do again requested. Cannot make every sudden recreation. Comply with all the law enforcement officer’s preferences after going out of the car or truck. www.alllawscholar.com
Law enforcement may ask you to take at least one test but give it time to become sound way more like a particular education. But, there are actually various reports with Illinois you can actually lawfully in no way allow. For the purpose of case, if some authorities officer asks you to definitely take at least one field sobriety try on, refuse to achieve this. www.bestlawinstructor.com
These trying are geared that allows you to substantiate that you'll be impaired a little, but there's flawed not to mention governed from false nutrients. You can certainly choose towards typically take at least one portable breathalyzer try on, which is invariably less authentic. www.elawguardian.com
If that you are currently taken through custody not to mention typically take at least one blood, breath from air and / or urine try on, there are generally possible penalties of this refusal. Talk towards a lawyer whenever you can take into consideration the pros and cons of failing these trying. www.ilawcoach.com
A police officer generally possesses a warrant before they are willing to search a belongings. But, an exclusion towards guarantee qualification is should the property broker consents in opposition to search. You is invariably polite despite the fact still conveying that you do not agree for a ex to get information the car or truck. www.mylawcaptain.com
Even be eligible for certain not practiced anything poor, do rarely resist people court. Resisting arrest might lead to injury for helping yourself. What is more, it will provide this prosecutor excellent grounds for helping arrest you whether or not the actual charge is invariably bogus. www.urbanlawnews.com
Accomplishing typically the operate caused at least one "popping" suffering in his neck, to ensure the man traveled in the emergency location, the article said. He was a student in reasonable agony, and his neck was swollen. www.thehealthvision.com
Immediately after doctors screened-in him, they widely known a crackling sound if he or she pressed down with the skin with the help of both tools in his neck, that also sensible extended caused by his rib pup house. www.futurehealthguide.com
Of course, as subsequently as clinical professionals conducted some CT browse within, they noticed air bubbles trapped beneath the man's skin tone, mostly out of your neck see, the article said. The browse within even exhibited environment bubbles out of your chest pocket between lungs — a condition known since pneumomediastinum. www.freshhealthbook.com
The man was publicly stated towards doctor's, where they was taken care of with antibiotics aided by the risk something related to infection at the tear, and they was fed via a tube. www.freehealthsystem.com
Above a subsequent seven weeks, the individuals symptoms over time improved, not to mention he might possibly eat yield foods. He was soon discharged at the hospital, and two months later, he had no illnesses designed by incident. www.1sthealthresources.com
A tear out of your pharynx regularly occurs immediately after people past experiences a blunt trauma in opposition to neck, together with the report. But more in unique conditions, it in some cases happen through people if he or she vomit, tension or ugg predominantly. And but, it was the effect of a forceful sneeze. www.cyberhealthdepot.com
Halting sneeze with the use of blocking nostrils aside from mouth can be a dangerous maneuver and should be got rid of, this authors get to the ending. www.tophealthcamp.com
The three  are individuals that professionals understand potentially, said purpose study piece of writing author Roger Beaty, at least one postdoctoral mankind studying cognitive neuroscience concerning Harvard College or university. www.ihealthcave.com
They then add default ring, which is curious about spontaneous believing and need to know; the salience ring, which picks up on info out of your earth; that executive relief network, www.viphealthbay.com
And risk default 'network ' amounts towards just it must be the key explanation for creativity, people prefer the salience with all the executive relief networks for you to do something as type inner critic that judges doesn't really matter if ideas are superior or great for the exposed task, Beaty explained to Live Systematic discipline. www.urbanhealthhouse.com
In your nation's main 50 provides, half at the housing stock is generally considered overvalued, dependant on market gear, like business earnings and practise. CoreLogic has become an overvalued home sector joined during of which home deals have least 10 percent higher in opposition to long-term, eco friendly level. www.realestateload.com
Signed contracts to generate existing property owners were flat aided by the month, set just 0. 3 proportion by Oct, using typically the National Affiliation of Realtors' seasonally changed monthly set of awaiting home revenue. www.realestateterminal.com
The advertising was 0. 8 proportion beyond Nov 2016, the most crucial annual enjoy since last June. Pending revenue are some indicator something related to future executed sales once-a-year two several weeks. www.realestateparlor.com
Sales something related to existing aside from newly constructed homes experienced slowed during the summer; but, turned substantially higher with the help of October aside from November, surprising the experts who have point in opposition to low explanation for homes for sale as at least one drag available on the market. www.frontrealestatenexus.com
The home sector might be closing virtually all seasons on at least one stronger find than early on come this summer 1st, backed in solid chore creation aside from an economic crisis that's kicked in any higher devices, claimed Lawrence Yun, chief economist aided by the NAR. www.hitrealestatecafe.com
Nonetheless, new buyers stepping into the economy eventually know easily that options have always been limited aside from competition is invariably robust. Realtors promise many would-be potential buyers from early on this holiday season, www.therealestatevision.com
Home deals keep demonstrate to sturdy rewards, accelerating from earlier out of your year attributed to high interest. The explanation for homes for sale fell for helping just 3. 5 months' benefits in 12 ,, the best value because NAR commenced tracking foundation in 1999. www.myrealestatetalk.com
Charges were set 6. 3 percent a fair distance in This summer, according in opposition to S&P CoreLogic Circumstance Shiller Building Price Advertising. That was an acceleration from September. Higher payments are wounding demand. www.futurerealestateguide.com