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Lender Guidelines for Appraisals... Can we keep up?

By
Real Estate Appraiser with Estimation Nation Corporation

ABC Lender Guideline Update - Appraisal Guidelines

ABC Lender is amending the appraisal requirements for all of its loan programs. The changes include:

The Maximum Distance for Comparables is 0.5 (Urban), 1.0 (Suburban), and 5.0 miles (Rural). Comparables that exceed the distances above will not be accepted. 

The Maximum Comparable Age is 3 months from the date of the property inspection as listed on the appraisal. One comparable may have a sale date not to exceed 6 months if the remaining two are within 3 months.

The Underwriter is responsible for including both of these changes in their review of the appraisal. If the comparables provided do not meet these requirements, additional comparables must be conditioned for. If the appraiser is unable to provide them, a Desk Review must be ordered.

An Appraisal Desk Review is also now required for all Second Mortgages, unless one was ordered on the First Mortgage. 

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So... how many Appraisers are going to a) call Urban properties Suburban because they comparables are more than .5 miles from the subject?  b) enter more than three comparables as it appears only two need to be within three months (I usually enter more than three in the first place)

When we start running into the off-season and where the housing market naturally cools due to the weather and the holidays, is this really a fair request? Isn't this what the sales date adjustment grid line is for? What do you think?

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 I got a new email today from a different company.... This is getting ridiculous!  I entered the requirements I find most offensive... especially the one regarding COD... Ummm, I believe that's not legal. Oh, I sent an email to clarify about not getting paid as well as the supervisory signature requirements.

Cost Approach
As stated in every order, the cost approach is required to be filled out in all reports. Please look in the
special instructions for the following verbiage concerning drive-by appraisals for specific clients:
IF THIS IS A DRIVE-BY ORDER, THE COST APPROACH IS REQUIRED
TO BE FILLED OUT. PLEASE COMMENT IN REPORT, "Appraiser is
completing the cost approach section solely upon the request of the client. The cost approach figure was based upon inspection of public records and, as such, the comparison approach would be considered the more reliable value."

Signatures
All reports are required to be signed off by supervisory appraisers
stating that you did inspect the interior of the subject and the exterior of the comparables. Included in the special instructions:
REQUIRED:  It is mandatory for the licensed/certified appraisers to complete an interior/exterior
inspection of the subject and an exterior inspection of the comps and sign the report accordingly.

COD
As always, it is the appraisers responsibility to collect the COD payments from the borrower / homeowner at the time of inspection. If you do not collect the payment you will not be paid. XXX Company guarantees payment on all orders placed as 'Bill', not COD's. If you experience resistance with collecting COD's please stop what you are doing and call XXX Company immediately so we can relay this information to our client. With every COD order you receive you will also receive an attachment. This attachment will be our credit card form which is specific to your order. If you do not receive this form please call us or reply to the email to let us know so we can get that form to you as quickly as possible. When you schedule the inspection with the home owner please mention that you will be bringing a credit card form with you for them to fill out and the appraisal must be paid for at the time of the inspection.

IMPORTANT: XXX COMPANY DOES NOT ACCEPT PERSONAL CHECKS. IF YOU ACCEPT A PERSONAL CHECK ON BEHALF OF XXX COMPANY YOU WILL NOT BE PAID OUT UNTIL THE CHECK HAS CLEARED. THERE ARE NO EXCEPTIONS TO THIS POLICY.

Michael Delp
Mortgage Pro - Telford, PA

With the slow down in sales, finding adequate comparables is becoming more difficult. Realtors and mortgage professionals aren't the only ones being affected in this market.

 

Oct 16, 2007 04:54 AM
Robert Elfand
Oviedo, FL
RAA

Sara,

I just received that same email, although I don't do much work for that company anymore.  In some of the more rural areas...I don't see this a viable request?  It appears that these "guidelines" handcuff an appraiser and will really add some extra thought before accepting the assignment.

Oct 16, 2007 06:26 AM
Sara Goodwin
Estimation Nation Corporation - Portland, OR
Portland, Oregon Appraiser

Hi Michael and Robert - The more rules that a lender puts on an Appraiser, the less likely a valid appraisal will come of it.  If the best comparable properties all sold 6+ months ago and I'm using mediocre comparable properties per the lender requirements, that really puts more negligence on me... I would rather do an honest appraisal and then get conditioned by the Underwriter later.  Don't even get me started on how difficult this would be for rural properties!

 

Oct 16, 2007 06:58 AM
Nick M.
Certified Residential Appraiser- West Palm Beach Real Estate - West Palm Beach, FL
Realtor-Appraiser in West Palm-South Florida Real Estate Appraiser

My concerns with these guidelines is the actual availability of comparables. In slow markets, there are NO comparables within the past 3 months... or within 1 mile. You can't make something up that isn't there.. and to use a sale that is newer but not as comparable as one that sold 6 months ago, well, that's just silly and limiting.

Surely Sara, appraisers will make the urban suburban or some other change so that the underwriters are happy. Don't get me started on those ethics!! makes me crazy!! Now the underwriters are pushing more of the liability on us so their files look better.. give me a break.  ps. i'm not ranting.. i'm just saying! :)

 

Oct 17, 2007 02:44 AM
Sara Goodwin
Estimation Nation Corporation - Portland, OR
Portland, Oregon Appraiser
Oh Nick... I know you would never rant :-) - Ethics and 'bullying' are two reason's I would much prefer getting a condition on the Appraisal after I have entered it (correctly).  That way, I have in writing exactly what they expect and the report shows that they were the ones to request the changes/manipulation.  I have yet to change an opinion of value due to a lender's condition... It just gives me a chance to quote what they are looking for and comply accordingly to the best of the information available.
Oct 17, 2007 04:31 AM
Sara Goodwin
Estimation Nation Corporation - Portland, OR
Portland, Oregon Appraiser
I received another list today that was added to the bottom of the original post...
Oct 19, 2007 03:13 AM
Sara Goodwin
Estimation Nation Corporation - Portland, OR
Portland, Oregon Appraiser
Thanks Mike (the drummer :-) ) - Perhaps I'll make a canned 'generic yet direct' statement on the addendum page stating that the Lender requests [insert above criteria here] and then the rebuttal as to why it would be incorrect or impossible to do that in the report.  That might hopefully dissuade a condition through underwriting and not prolong the loan.
Oct 20, 2007 04:55 AM
John Fariss
Fariss Appraisal Services - Bakersfield, CA
Appraiser - Bakersfield, CA
I love the requirement for the cost approach on a drive-by...that will be an accurate component of the report. I've had underwriters requiring all comps be within 3 months too. I even had one ask for 60 days. Didn't the underwriter see at the top of the sales grid that there have only been 10 similar sales the whole year? I guess they just want you to keep going further out or using homes that have less similar characteristics. It's always something.
Oct 25, 2007 10:28 AM
Sara Goodwin
Estimation Nation Corporation - Portland, OR
Portland, Oregon Appraiser

John - The more we are asked to narrow down our results, the less accurate it will be - I have no problem entering six comps in a report - three within 90 days... no problem, but the other three will likely be more like the subject and might be over 6 months old (*gasp!*)  Our market is stable and has not seen the bursting bubble, but we still get the same requirements (no matter how much documentation I put in the appraisal report giving trends and statistics).

Michael - I'm just having a problem working on my finesse.  I don't take offense to some of the conditions presented, but it really chaps my hide when I have covered a potential issue in the report, but the Underwriter either neglected to read it or the paragraph that I put in there wasn't sufficient enough. Still working on my attitude and ability to 'bend over' without question. 

Oct 26, 2007 09:33 AM