Homebuyers Crash Into Appraisal Roadblock
In the wake of the recent collapse in home prices, appraisers have come under fire for bowing to lender demands during the boom, offering up property values more aligned with lenders' wishes than with reality. In 2007, the state of New York sued Washington Mutual -- now owned by JPMorgan (JPM) -- for colluding with a subsidiary of First American Corporation to overinflate home values.Collusion between appraisers and mortgage brokers, real-estate agents, banks, and borrowers helped fuel runaway price appreciation. In response, Fannie Mae (FNM) and Freddie Mac (FRE) -- the 2 government-owned giants that control around two-thirds of the mortgage market -- issued new guidelines dictating how lenders can select and evaluate appraisals. The new policies went into effect May 1.
To help facilitate the new, tighter rules, lenders are using appraisal management companies, or AMCs, which employ networks of appraisers around the country to provide what purport to be unbiased value analysis. All this, of course, comes at a cost which is ultimately borne by borrowers.
And, in what could be considered ironic if it weren't so repellent, appraisers are crying foul.
This from a group whose moral backbone during the housing boom most closely resembled that of a jellyfish - one seemingly incapable of preventing its members from being wooed by banks into committing fraud.
An appraisal is simply one person's opinion of a home's value on a given day. And although that person is licensed to provide such an opinion, the very nature of an appraisal renders its usefulness as a true risk management tool questionable at best.
The growing use of AMCs, opponents argue, reduces appraisal quality even as it increases costs. Appraisers are selected based on proprietary quality scoring mechanisms employed by each AMC, which may or may not be a good measure of reliability. And since AMCs take on average a 40% cut on the total appraisal fees and lenders demand quick turnaround, appraisers are working for less on a tighter timeline.
Sure, fraud may be reduced, but incompetence could more than make up for that as AMCs scramble to employ barely capable appraisers in order to ensure complete geographic coverage for their clients. The real losers in all this -- as is the case when poorly conceived regulation is aimed at making up for past mistakes without proper consider for the root cause of those mistakes -- are homeowners, who must now pay more for a property valuation mechanism that isn't likely to be much better than the old one.
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We are seeing huge valuation problems with both refinace appraisals and purchase appraisals right now. Not just with values being off a little bit...I've seen appraisals come in 10% or more low... mostly because the appraiser didn't understand the area. Some neighborhoods, streets, or blocks have more cache and value than others within the appraiser's 1-mile radius search for comps. Without intimate knowledge of a town, there is no way that an appraiser will do an accurate job.
In the past, if the value was going to come in low, the appraiser would talk with the mortgage broker and with the real estate agents involved to try and get the most accurate value. Sure, there was fudging involved sometimes...but at least the appraiser was well-informed. Most chose to be ethical. Now, agents and brokers can't talk with the appraiser...meaning there is no chance to correct a flawed appraisal before it is submitted to the bank.
And, correcting a bad appraisal after submission has been a hightmare. Because banks are backed up with refinances, challenging low appraisals can take 2 weeks instead of 2 days.
This puts home sales in an unnecessary state of limbo.
It would have been much better to let the banks weed out unethical appraisers on their own than impose this AMC "solution".
I have seen $50K of such expenses rolled into the selling price of a $250K new home.
Buyers need to beware of appraisals based on recorded prices of new home sales.I do not have experience with existing home sales,so I can't say whether the problem exists there.
There needs to be a rational measure of the market value of the lot and the direct labor and material.
If you look for a rational basis for real estate prices based on land, labor and materials cost you'll find that prices need to drop 40 to 60 percent from their current levels to reach replacement costs. When the issues surrounding the questions posed by that conundrum become clear and you understand why it is that way and who profits from this situation get ready to look at the world in a whole new light.
waaaaaaaaaaaaaaaaaaaaa
I agree the new system sucks, is REALLY STUPID and makes appraisers basically salute with the middle finger to the AMC - thief
OTOH I also believe the banks need to be allowed to fail
they milked the recent refi boom and DID NOT HIRE ONE PERSON
My friend has 10 escrows going and CANNOT GET LOAN DOC's from the BANKS
appraisals don't seem to be any problem for him though - as his buyers offer MARKET
but banks don't care and will make far more with the rates up 1.5% in past month
so delaying means locked rates - expire
we haven't seen anything YET folks
I just did a deal - 17 days from 1st look to closing - eezy peezy and I get a nice 40% LTV note too!!!
Owner financing is the only way to go today
Asking the Banks to maintain ethics is like asking Roaches to exterminate Rats.
The "good ol boy" system continues to exist. The use of AMC's is good if it is allowed to operate freely with no pressure from the "good ol boys". Unfortunately, the "good ol boys" are raising hell because they no longer can control the flow of appraisal work to them. However, the AMC's are caving in to them and letting the banks just forward a list of their "good ol boys" appraisal list to them and the AMC's are even paying them higher fees than their other "less fortunate appraisers" who have worked for the AMC's for years past.
Forty three years ago, if you were not born with a silver spoon in your mouth then you could not get a job in an appraisal company. The banks required that an appraiser have either a SRA designation or a MAI designation to do work for them. These are the same "good ol boys" that party with them at the country clubs, tennis clubs and yacht clubs, etc, get my drift. So a new college graduate with a double major in real estate and economics trying to get into the business and not born with "blue blood" hardly had a chance. You were told if you were not a SRA or MAI, they could not put you on the bank, FHA, or VA list of approved appraisers. Ironically, you could not get those designations without appraisal experience. Guess what? If you could not get a job with an appraisal company because of who your parents were, then you could not get the required experience.
Fortunately for some of the less fortunate, there were some smaller lending instituions who were willing to give you work if you had the qualifications and education. There are some appraisers who have found a niche with the first AMC's and provided a service and in return were able to gain experience and designations and earn a living.
Now the worm has turned again. The banks, mortgage companies, VA, FHA, all who formerly refused to add qualified appraisers to their list ( by the way the VA still refuses to add appraisers to their list unless you have pull)are now required to use third parties to order their appraisals. But with the help of certain organizations, power brokers, lobbyist and politicians, the "good ol boys" are screaming their lungs out supposedely to help the poor consumer and yellng "foul". Not because of bad appraisals, but because their pocket book is being hit. Yet they are the very ones who have all the lenders and banks in trouble again with bad or fraudulent appraisals. The same "good ol boys" in lending who got their best country club friends to put the "value needed" are sending their same "good ol boys" appraisers list to the AMC's to send assignments to so they can circumvent the intent of the HVCC regulation. Think they will be discussing that appraisal and loan over drinks at the country club or yacht club?
So, what will be the results? The "good ol boys", because of their country club friends and political clout will prevail. They will continue to give their appraisal assignments to their friends and the same cycle will start over again.
Are there some appraisers who should not be in the profession who are not part of the "good ol boys"? Definitely. They need to be weeded out and if the lenders were more concerned about the loan portfolio than they are about getting a "certain value", then the evolution of not giving appraisal assignments to these appraisers would remove them from the profession.
Those appraisers, who over the years have held on to their values, morals and professional ethics, struggling to eke out a living, will hopefully continue to survive. However, if the "good ol boy" system prevails, then it will be status quo in the coming years. The national and state requirements are being set so that, unless you can afford a college education and time to take additional courses and not worry about making a living to support yourself and your family, the appraisal profession will be very limited in numbers and those who are not born with a silver spoon in their mouth will look elsewhere in lieu of the appraisal profession. There are some very qualified people in the society who are not fortunate enough or economically able to attend college who deserve a chance to become an appraiser. There sre some appraisal company's out there who hold to their professional ethics and standards and do not cave in to pressure that can help these individuals become good appraisers. However, the future looks bleak for them in todays world of the appraisaing profession.
So, what is the answer. Remove all those people from all the Boards and Regulations setting committees that have a vested interest in keeping the appraisal profession limited to the ones born with a silver spoon in their mouth. Remove all contact between loan officers and the appraisers, with strict penalities if violated, and do not allow lenders, banks,etc, to furnish their list of approved appraisers to the AMC's. Allow the AMC's to do what the professional organizations have neglected to do. Monitor and clean out the ranks of ALL those who claim to be appraisers. Not just those who are not part of the "good ol boy" system.
Unless this happens we can just look for more of what has happened in past cycles.
Borrowers also need to be protected from paying too much for a home. I know-"buyer beware", but we are talking about the single largest monetary transaction in most people's lives. and they need an unbiased opinion. Here is the rub. For years appraisers and lenders have been working together to get the deal done. Any appraiser who would dare to "kill" a deal was destined to be a very hungry appraiser.
This is where the new HVCC, or Home Valuation Code of Conduct has come into our lives. The idea of the HVCC is to stop the pressuring of appraisers from being influenced this way by the ordering of appraisals through third parties called AMCs or Appraisal Management Companies. The problem is that many lenders are creating their own AMC, keeping their good old buddy network of toadies(appraisers who will play ball) on their "approved appraisers list" and taking a larger piece or the fee(which has gone up.....alot!)
Realtor = 1st grade education (know how to color inside the lines), 30 hours of classes, pass a test, and VOILA, you're a Realtor that knows better than anyone else how to value property.
Mortgage Broker = 1st grade education (knowing not to go pee pee in your pants), 20 hours of classes, pass a test, and POOF, you're a MB. Now you too know better than anyone else how to value property.
APPRAISER = College Education, 250 hours of classes, 2,500 hours of direct apprenticeship (hour-for-hour logged experience, not pouring coffee in an appraisal office kind of experience either)
SOOOOO, YOU'RE FREAKING KIDDING US RIGHT, GREG??!!
Valuing properties doesn't require hundreds of hours of education. It requires integrity and the ability to put yourself inside the shoes of a potential buyer. They "art" to valuing properties is picking the comps, and any appraiser (or agent for that matter) would tell you that comps can support a value 10-20% above or below market, just based on how you pick them.
Are all appraisers/appraisals bad? No, but very few are truly unbiased, and even fewer offer the type of integrity indicative of someone who takes pride in getting it right.
FHA is the new source for new subprime lending. Yes, it still exists. The FHA actually called us and wanted us to find a "new" appraisal to fit a deal that wouldn't work. Yes, that is the "new" FHA and it is happening today.
Home prices are heading down - take a look at 1998 - that is where the bottom will be. You can look at the long term inflation-adjusted Case Schiller data, you can look at the relationship of income to RE value and you can look at the relationship of rent to housing prices - they all point to the same thing. Think 1998. If you own RE, just check what your home was worth in 98 - that is where it is headed.
This is what is causing the problem with appraisals. As prices fall, appraisals are very difficult to make.
With the government over 90% of RE activity and the pace of changes in rules and regs happening weekly - often daily - I see periods of dislocation in the RE lending process that will cause the system itself to seize up periodically.
Think Amtrak. Sometimes the trains run, sometimes not.
It is getting uglier by the day.
The net result of all of this is that very educated, experienced appraisers, some who have built relationships for decades and yes used to "business as usual" cannot get with this AMC thing. Like myself most are unwilling to or cannot live on a reduced income brought on by sharing their fees with an entity that does little more than forward an email. (assignment). The entire industry will be lose qualified people to complete complex appraisals. We in the industry know that education is just a small part of this puzzle. It takes years of appraising , every type of property to become proficient in the process. Every property is different. Couple this inability to market your business.... lets face it what other industry is dictated to and regulated to such a degree that you cannot speak to your client, and with so much liability. So the net will be that there will be many old appraiser's (like me ) out looking for new careers, and a real difficency in the industry. Every one will pay for this.... not just the homeowners..... every facet of the industry is going to suffer from all this regulation, and by the time they figure it out... the damage will be done.

















