Contrary to Popular Belief, the Appraisal is NOT a Commodity

Monday, December 2, 2013

Many mistakenly view the appraisal as a commodity. True, there are several traditional methods that every appraiser must go through when determining the value of a home that may make the appraisal seem commoditized, including researching the market, analyzing comparables, inspecting the property and making appropriate adjustments to the comparable sales. But those methods are exactly why the appraisal is NOT a commodity. In reality, it is a myth that all appraisals are more or less the same, even though it may seem so at first glance.

The main consideration for a residential appraisal is the value it provides in terms of risk management. Unfortunately, not every appraiser understands how important their role is in the effort to manage risk. In today's highly regulated industry environment, lenders are fully aware of the value an accurate appraisal provides not only for underwriting purposes, but also in establishing a solid record of accurate property valuation. Lenders are keen to have proven sources for appraisals that deliver precise valuations that can withstand third-party scrutiny. Appraisers who can provide accurate and timely property valuations certainly distinguish themselves from competitors.

Proper risk management can be grouped into three key elements: properly analyzing the market, having a complete working knowledge of state and federal requirements and providing thorough explanations within each appraisal report. By incorporating these three elements, the appraiser should meet the minimum requirements of an appraisal and help establish them as a knowledgeable resource.

It is crucial for appraisers to not only familiarize themselves with the market they are to research, but thoroughly analyze the area and understand its intricacies. It is not sufficient to rely on one or two evaluation tools. Rather, they must combine them with as many alternative methods as possible to ensure complete accuracy. When appraisers review and study multiple resources all pointing to the same conclusion, they know they will have the most accurate report.

These resources are available through a variety of channels. There are a number of valuation technologies to help analyze the market, such as Collateral Valuation Reports (CVRs), Automated Valuation Models (AVMs) and Residential Evaluation Reports (RERs). However, these tools should only be used as a supplement - not as a substitute - for an opinion of value. Also, public records are readily available for appraisers to use in their research. Online data sources like MLS, RealQuest, Zillow and Trulia provide a decent snapshot of the area, but must be reconciled. Equally important to familiarizing oneself with the right market is to identify the proper market segment for which the subject property falls within. Comparable properties may seem similar on paper but are vastly different when it comes to quality and features; therefore, accurate comp selection is a primary risk management factor. It is extremely important for the appraiser to "know" the area. That means having a solid, working knowledge of the area in order to select the correct comps that justify value.

A full understanding and application of state and federal regulations is another way to assure the accuracy of the appraisal. Not having this knowledge jeopardizes the success of the appraiser's business and puts the lender at risk of fines, penalties and failed loans. Having an expert familiarity with the Uniform Standards of Professional Appraisal Practice (USPAP), Consumer Financial Protection Board (CFPB) regulations, Appraiser Independence Requirements (AIR) and individual state laws is a prerequisite in order to properly perform the job. It is not good enough to know one set of laws, but to fully understand all the requirements associated with appraisals. If appraisers are found to be out of compliance, they risk severe penalty fines and can be shunned by the industry on future assignments. Appraisal management companies are now required by the Dodd-Frank Law to report to the appropriate board appraisers who are breaching such rules, and at that point the appraiser's license may be pulled. They also put the lender at risk of penalties and fines.

The third method of comprehensive risk management is to be able to provide more details within each appraisal report, such as a clearer explanation of each and every anomaly. Any time there is a lack of data relating to how the subject property compares to a neighboring property, that deficiency must be spelled out in the appraiser's report. Good appraisers try to preempt any possible question from the underwriter by disclosing upfront the information they used to determine their conclusions. In the current lending environment, underwriters are much more conservative and are quite specific in their program guidelines. Therefore, appraisers must consistently provide more detailed commentary to describe their rationale for any and all anomalies. This will accelerate the process by reducing errors and kickbacks from the underwriter.

It is inevitable that at some point an appraiser will have comps that are either all superior or all inferior to the subject, and he or she must make an adjustment and explain why. In such cases, the commentary in the report would explain that the appraiser failed to find better comparable sales by expanding the search in distance and time. An additional explanation for the rationale of the adjustments is needed as well in these cases, utilizing either a historical analysis of the market data and applying that to the current environment or conversations with local real estate professionals in the area.

The appraiser can offer no more important service than having a real, working knowledge of the properties he or she is appraising. That means driving around the neighborhoods, exploring the areas and understanding the particular nuances of the locales they are servicing. That is the real differentiator and added value between an appraiser and an automated model.

The best appraisals are not commodities. Those appraisers who understand this and enhance the process by incorporating risk management will be more successful by providing high quality, well documented valuations that expedite the mortgage process.

Roger Beane is CEO of LRES, a national provider of commercial and residential valuations and asset management for the mortgage, banking, credit union and real estate industries. For more information, visit http://www.lres.com

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

Comments

I agree with most everything in this article! But all I read these days is what the lender wants, the additional effort that needs to be made to complete a quality report, I get it! The problem is we as independent appraisers are a business first! The lenders require "narrative" reports, do not allow anyone else to help with the field work, want shorter turn times, have increased the scope of work five fold, have increased the appraisers liability and have none of their own, and reduced the pay - to the appraiser. They have taken complete advantage of the struggling oversupply of appraisers that resulted from the mortgage boom and the underhanded practices of some lenders back then, by offering more work to certain appraisal offices that could handle the work, regardless of how many licensed appraisers that appraisal office had. (50 a week with two licensed appraisers?????). In return the licensed appraiser gave his "data collectors" double the amount of experience hours to get approved for a license. This is how we have so many licensed appraisers that can't explain anything! Its these same appraisers who have no clue as to what their price point should be for an appraisal vs. their expenses. In the meantime, everyone else is making more money, the banks, the AMC's and both use the "guilt trip" on appraisers that their not adequate appraisers or are violating USPAP. USPAP says you cannot charge more for an appraisal unless it is considered "complex". Business 101 and American free enterprise says that if an assignment is going to take me twice as long to complete because of "appraisal problems" (no comps) that don't have anything to do with the property being complex, I should get paid for my additional time. If I complete a report and the lender wants me to answer to everyone that reads that report down the pipeline, I should get paid for the extra time. We're not mind readers! We' can't anticipate every question that may come from people with no valuation knowledge vs. moderate! After an attorney consults his client he's not expected to consult with every other family member for free!!! I interviewed for a staff appraiser position with a large AMC. They old me that I would have to complete "12" appraisals a week, which is impossible in my high end area even with 28 yrs. experience. When I questioned the interviewer, she replied "well, that's what we need to do in order to make a profit"!!!

Everyone seems to acknowledge that it is most desirable for the appraiser to provide a work product that appropriately addresses the specific valuation issues of the property being appraised - not a cookie cutter appraisal job that ignores difficult issues that may be present but inconvenient and/or time consuming for the appraiser to address.

There is no agreement, however, on how the appraiser should be treated by the client for this work that everyone agrees is so important. Appraisers believe they do custom professional level work and should be treated and paid accordingly. Some lenders and AMC's agree, but many others believe that appraisers should be treated as unskilled workers likely to make errors and in need of constant supervision, often by cookie cutter computer programs that check for "errors" and then let employees with no or minimal appraisal experience contact the appraiser to demand that the reports be "corrected" to conform to the cookie cutter model. The appraiser is put in a difficult position. The appraiser may "give in" and change the appraisal to reflect what the contact person says they want (or maybe just do it next time the way the contact person suggests) or they can fight the good fight and advocate for sound appraisal practice that accurately and appropriately values the subject property addressing significant valuation issues even if this does not produce a cookie cutter appraisal desired by the client's review process. It goes without saying that, to fight the system, the appraiser will bear the financial cost of extra time and effort to placate the "reviewer". Eventually this wears out many of the "good" appraisers and they either leave the profession or just give in and produce the cookie cutter reports so seemingly desired by some clients. In this environment it is a small and easy step to: "If they don't care why should I?"

There is also the matter of appraisal fees. In all other professions it is widely acknowledged that superior expertise and service comes at increased price. Even in construction, if you want a bigger house with more custom features it costs more. Only in appraisal is there the attitude by some clients that a fixed cookie cutter fee should be paid for all residential appraisals regardless on the time and effort required. Is it any wonder that cookie cutter fees eventually result in cookie cutter appraisals?

The puzzling thing is that so many AMC's, lenders and regulators publicly profess that the current system works to produce accurate valuations suitable for realistically evaluating risk. Maybe instead it simply masks problems and risks better than ever before.

an independent opinion of value, is a low risk investment itself when a person(s) or company, etc. is researching a prospective investment, and is hopefully completed by a professional and competent appraiser. It never ceases to amaze me how many types of appraisals there are out there in the world and yet, residential (and commercial) appraisers are put under such a microscope that we can't even breathe anymore! I've concluded that residential appraisers are people that take real world "market value" data/scenarios/ motivations/circumstances, etc. and try to squeeze them into over regulated "guideline values" all under the name of risk managment...and...at the same time, being held responsible for making sure the general consumer and the Regulators understand everything we've done in a report. Hello?!?!?! either you want to make the loan or you don't, either you trust the appraiser or you don't!!! Risk management has nothing to do with increasing natural disasters or continued guessing about an economic crisis! or the biggy, homeowner mistakes like leaving the water on upstairs and flooding the whole house. While statistics may help lower the stress level of a risk investment, that's all they are, a statistic. What's valued today at one price can be valued tomorrow at something totally different. Motivations and circumstances are changing overnight, the seller/buyer world is getting smarter and people are wheelin' and dealin' like never before to get the best deal. Heck, I read a Realtor (of 14 years) comment today where she stated "a third party appraiser informed the mortgage company that finished basements can't be included in the total GLA", Hello?!?!?!?.....again....does anybody else see anything wrong with this? Why are appraiser's the only ones privy and/or mandated to FNMA, FHA, blah, blah, blah guidelines? If we have to know and follow them, why shouldn't everybody else in the industry! Why, because the market does not recognize "regulated guidelines" and appraisers report the market not guidelines! When's the last time anybody saw a buyer make a comment "well, since a wee bit corner of the house is below grade and therefore under the regulated guidelines, a basement, my offer is $X". I just wish people would let real estate appraisers be real estate appraisers and let us report market values without trying to squeeze them into "guideline values". Risk managment? commondity? HA! it's an independent opinion of value! nothing more, nothing less, either you like it or you don't, either you make a loan on it or you don't! It really is that simple! Why the constant "chasing of tails" as to what an appraisal is or where the "new valuation" process's are headed? It still boils down to what someone is willing and/or most likely to pay for something! and hopefully, based on having some knowledge of what their willing to pay for! I love appraising for what it truly is in it's simplest form and purpose, and not what others try to make it!

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