Is It Time To Take Control Of Your Appraisal Management?

Friday, December 14, 2012

Reprinted from MortgageOrb

Yesterday looking through the Appraisal Buzz Twitter feed we stumbled upon this great article by Jennifer Creech published HERE by MortgageOrb. We thought this was a fantastic article and wanted to make sure to share it with all of our readers. We hope you enjoy it!

It doesn't take a Type-A personality to want control over the appraisal effort. Nearly all lenders are concerned about their processes these days for a very good reason: the buck stops with them, whether for consumer complaints, compliance issues or repurchase demands from investors. The lender is ultimately responsible for the quality of its origination processes, and that includes the quality of the third-party work that goes into making each loan.

Internal appraisal departments never completely disappeared, but they have not been the rule in a long time. Lenders have relied on outside appraisers for decades, and this has worked well for millions of loans.  The appraisal is among the most important and subjective documents in the loan file, so it is frequently cited when buybacks occur - more than a third of the time, by most estimates. It is also the victim of fraud, as is the appraiser, when data pools are clouded by flipping schemes, short sale scams and other spurious transactions.

It is easy to understand then why more lenders seek greater command over their appraisal efforts, but they are squeezed by competitive pressures on one side, and by quality control and regulatory pressures on the other. Where they once were content to largely outsource the entire appraisal function to appraisal management companies (AMCs), lenders are now looking for better ways.

AMCs are very convenient as a nuts-and-bolts means to replace the old-school appraisal department, but that convenience can come at the sacrifice of hands-on confidence. Moreover, there are the ever-present compliance issues.

Many sizeable lenders, including at least one top-10 bank, have recently taken their appraisal programs completely in-house, managing individual orders and appraiser panels themselves. It might make sense in theory, but in today's corporate environment, it is not an option for many lenders. What can a mainstream lender do to gain the needed control without running up costs and sacrificing competitiveness?

Flex appeal

As transaction volume heats up in the low-rate environment, flexibility is important for all lenders, but with national and growing regional companies, it is a must. Panels of approved appraisers need to be developed, scrutinized and meticulously maintained, with licensing and quality checks an ongoing way of life.

In some areas, like those close to the home base, this is more easily accomplished than in growth and expansion locales. In those places, using AMCs may be the best way to go, whether for retail or wholesale transactions, as long as their reporting, metrics and quality-control results pass muster. In other areas, a blend of in-house and managed appraisal services may offer the flexibility the lender needs.

Flexibility is critical in the overall appraisal effort, particularly when there are origination or bank branches demanding uncompromising service levels. Internal systems and outside resources can blend harmoniously - if a lender uses technology to bring it all together to provide quality control, delivery and panel management oversight.

The best technology platforms can also handle the commerce aspects of the appraisal program, collecting fees and paying appraisers with automated ease. The end game is gaining the ability to manage a virtually limitless number of appraisers and AMCs simply and efficiently.

Staying compliant

Compliance is obviously a place no one wants to be found wanting - it is not only a matter of keeping within the lines drawn by regulators, lawmakers and the Dodd-Frank Act, but it is also about staying on the right side of buyback letters from the government-sponsored enterprises (GSEs) and staying off the consumer litigation radar screens. With the evolving appraiser guidelines from the U.S. Department of Housing and Urban Development designed to keep appraisers objective and unpressured, and the growing concerns of appraisals being influenced by imperfect data, compliance is not as simple as not doing something wrong. It is an active concern that is best addressed by constant vigilance on quality, with metrics enabling painstaking analysis and rules-based triggers on red flags that arise.

Appraisal management technology platforms can provide great utility to make compliance simpler and less stressful. At the same time, the best technologies call for human intervention when it is needed, such as when comparables stray from optimal parameters or when transaction participants' names come up on databases that cause concern. With hundreds of local, state and federal laws still waiting to be created under Dodd-Frank, compliance will certainly become more difficult long before it becomes simpler.

But this raises more questions: How much should appraisals cost? And are consumers paying a premium for the AMCs' services when there is no apparent value to homeowners?

These are issues that have been debated since the first rumblings of the Home Valuation Code of Conduct rules and their more stringent successor, the Appraiser Independence Requirements, began. Section 1B of the requirements seeks to keep appraisers free of all manner of undue influence from parties on which they depend for compensation and future business. This is all intended to benefit consumers with greater appraisal quality, but it creates competitive pressures for lenders, too.

AMCs provide their intermediary services for a fee, and in the past, this amount has come, for all practical purposes, from the appraiser's share. With fee splitting now limited, the AMCs are charging their fees separately to stay compliant, but the funds have to come from somewhere, and that is most often the consumer.

A slow market has kept appraisal costs fairly steady for consumers over the last few years, but many appraisers would argue that they are ultimately the ones making up the difference. Technology can reduce AMC costs with lower administrative headcount, enabling narrower margins that lower-tech AMCs find hard to match. Lenders wanting more control, compliance and flexibility have noted this and are looking to technology for solutions.

With the right platform, lenders can become their own AMCs and save the middleman expense, replacing it with a compliant service set that is available at reduced costs. This offers opportunities for either a competitive advantage or additional income, while keeping the flexibility to use outside AMCs where needed to serve unfamiliar markets. However, keep in mind that AMC fees can often amount to hundreds of dollars per loan.

Control is highly desirable when you are held responsible for every aspect of your product. Appraisals are too often the disputed element in repurchases, and as a key component that is prepared outside of the lender's influence, its processes bear close management. Oversight is already in place from the investor side via the Uniform Collateral Data Portal and the GSE requirement for submission prior to loan submission. It makes a great deal of sense to use technology tools to keep a close watch on appraisals from start to finish.

Technology brings us amazing efficiencies and process improvements, but sometimes they come at a price: long implementation times, hidden expenses and unforeseen complications. In today's Internet-based world of cloud delivery and user-friendly software platforms, appraisal process management technology is highly accessible and easily adopted. Flexibility in the appraisal effort has never been so readily attained, with compliance and competitive enhancements included to help lenders deal with their often-hostile environment.

Lenders concerned about control no longer have to consider bringing appraisals completely in-house in order to achieve true command over the process. And that's good news for everyone in the organization - Type-A personalities included!

Comments

No doctor, or surgeon, or lawyer, or engineer, or any other professional person would work under this much scrutiny for the amount of pay we get as appraisers.  When banks make loans they collect origination fees and then the interest or up to 30 years to come.  Appraisers on the other hand are putting themselves at risk for a minimum of five years and recently even more for as low as a couple hundred bucks.  Let's see, does it take a rocket scientist to figure this out.

Per your article, based on your 23-years of experience, government legislation, technology, market changes and the "lenders" own actions have created the very situation these lenders are now attempting to find an answer to. Now that the "buck stops with them," they are being held responsible for their business practices. For years they transferred liability to the AMC only to have legal precedent negate the viability of that approach. Based on recent legislative changes, they are now truly responsible for each loan they make, which should have been the case all along. The real issue is that every lender and AMC have diminished the appraisal industry to two factors, FEE and TURN-TIME. This has degraded the appraisal profession because most valuation assignments are being sent to the least-experienced and most desperate appraisers who will work for a fraction of a customary and reasonable fee. As a diversified real estate professional who continues to work in the appraisal profession, I have found that no AMC or lender EVER asks about my educational background, geographic & property type competence, years of experience, designations or recent experience in that market area. Those critical factors are not important to lenders, but they most certainly should be in our current environment. Only how low of a fee I will take to pad their profit margins or how quickly I can rush through my professional due diligence to expedite getting them a quick appraisal, often to make up for the lender's incompetence that has necessitated the RUSH order they are now hurrying to assign. My 25-years of experience in the overall real estate industry has seen the degradation of the appraisal profession where the assignment conditions and scope of work have exponentially increased, immediate and long-term liability has significantly increased, the cost of business has increased and yet appraisal fees have been stagnant at best or declined over the past 5-10 years. The appraisal "profession" is no longer viable due to these factors as indicated by the attrition the industry is currently experiencing. The average age of an appraiser is increasing coupled with fewer entrants in the business and fewer trainees, along with on-going technological changes that will eventually make the appraisal profession obsolete. Given the context of the entire industry, why would any rational person currently enter the appraisal business? Answer: they're not. Interesting article, but what is an "appraisal effort?" Lender jargon? i.e. turn-time.

'AMC's are convenient for lenders." The problem is that they are getting the cheapest appraisal and the shortest turn time. In a few years all these bad loans will come out again and the whole industry gets blamed. What many lender's are starting to do is go back to having there own appraisal depts. and order quality appraisals from qualified appraisers. As an SRA I have been getting a lot more direct calls from lenders and the fee that I have been quoting has been acepted. It seems that may fee is less than what lenders are being charged by the amc's, who have been over charging for poor appraisals.I have been in the business over 25 yrs. and this industry has always gone full circle and always back to the well qualified appraiser. There is always work available for good appraiser's.

I work almost exclusively for "inside AMCs" who maintain a roster of reliable appraisers and pay us 85-100% of VA rates.  I receive & decline daily orders from "outside AMCs" who maintain a roster of desperate appraisers and typically offer 40-60% of VA rates.  The latter need to be put out of business as soon as possible in order to protect the entire residential lending industry from the consequences of their predatory abuse of desperate appraisers.  I do however work for one "outside AMC" that is non-predatory (typically pays 80% of VA rates).

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