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LOVE GETTING TIPS TO OVERCOME APPRAISAL HURTLES

By
Mortgage and Lending with Mortgage Consultant, Right Trac Financial Group, Inc. NMLS # 2709 NMLS # 6869

“Love Getting Tips to Overcome Appraisal Hurtles”

I want to share a recent appraisal experience that was extremely frustrating.

Overcoming appraisal hurtlesA Realtor referred a client, pretty simple transaction. Sale price was $335,000, borrowers were putting 20% down, plenty of income. Like I said pretty simple, until we got to the appraisal. The appraisal came in at 324,000. The process today is that a copy of the appraisal gets sent by the appraisal company to the client and to us. The client was not a happy camper and talked about backing out.

We sent copies to the two Realtors and requested they review the appraisal and I would do the same. The numbers didn’t make any sense to me, as the comparables that were used, would easily show the value at the sales price or higher.

Bingo, the calculations were wrong and needed to be corrected. Here is the problem. In the infinite wisdom of HVCC and now Dodd-Frank, the mortgage broker cannot contact the appraiser. They must be afraid that we have the ability to corrupt the integrity of the appraiser. RIGHT

So, I asked the two Realtors to contact the appraiser to ask that the calculations be reviewed as there was an obvious error. The appraiser eventually acknowledged the problem, but the process took 9 business days to get resolved, because of all the red tape.

The system is completely broken and needs to be repealed. Let  me know your thoughts or experience with the appraisal system.

 

Tips to Overcoming Appraisal Hurtles

By: Frank Danna

The valuation industry has been infused with a host of regulations, standards and consequently, scrutiny. Of course, these regulations were implemented to bolster a sector of origination riddled with challenges. Quality was suffering; independence lines were crossed within a lending institution at the cost of the appraisal report, and ultimately the loan itself.

The appraisal independence requirements within the Dodd-Frank Act go a long way to shedding more light onto an issue that needs to be solved, but it doesn’t go quite far enough. The regulatory bodies that govern our space—CUNA, FDIC, Consumer Financial Protection Bureau, etc.—have jointly issued a statement, “The Interagency Guidelines,” that incorporates all of Dodd-Frank as well as additional, critical guidelines on achieving true appraisal independence and the methods/steps an institution should take in order to be truly compliant.

Within the guidelines, it is illustrated how an institution can gain not only complete compliance, but also satisfy their safe and sound banking practices as well. This is critical to an industry that is struggling to regain footing. If addressed appropriately, a lender can overcome some of these most common industry hurtles with ease.

There are several takeaways that lenders can implement to strengthen their compliance posture and ensure a high quality appraisal report: focus on compliance, instill higher levels of quality control, support reasonable and customary appraisal fees and appropriately use appraisal management software. Should a lender choose to outsource appraisal independence to a third party, most of that burden will be alleviated.

Compliance concerns are excessively burdensome on the banking industry. So much so that most banks have separate compliance departments working meticulously through ever-changing compliance applications and modifications. These departments can certainly interpret the applicable regulations, create the necessary operating procedures and apply to the individual department segments, but there are weaknesses in implementation and day-to-day management of the proper compliance procedures. This is most commonly the result of unqualified and / or uneducated staff.

As required by the regulations, "the individuals working in the department must at a minimum, be trained, qualified and understand the AIR and Dodd-Frank Act, appraisal regulations and enforcement, as well as the Uniform Standards of Professional Appraisal Practice."

One of the main hurdles in today’s lending environment is maintaining appraisal quality levels. To overcome these challenges, all completed appraisal reports should pass through a multiple-stage quality control review process prior to delivery. When the appraisal report PDF is delivered it should be reviewed extensively for completeness, correctness, consistency, compliance, and cross-checks so that the lender’s processing department can use it most efficiently as an aid for underwriting and pre-underwriting. A visual review is crucial in this process. Technology alone cannot uncover common appraisal mistakes, such as missing photos, signatures, location map flags and sketches.

Higher fees to appraisers will result in higher quality reports and reliable service. The interagency guidelines recommend compensating appraisers according to reasonable and customary fees in the specific area or market of the service. A higher-paid appraiser will result in a higher quality appraisal report; a win-win for the lender since the cost is passed directly on to the borrower.

This is crucial in the selling process of a loan product. Often, HUD-1 fees can be a breaking point in negotiating a loan for a borrower. Appraisers and banks know their market and borrowers better than anyone—this is why it is crucial to work closely with both the appraiser and the lender to develop a market-specific pricing schedule for the particular region.

Technology plays a large role in all facets of banking, including appraisal management. There are several providers of appraisal management processing platforms, including loan origination system providers, all of which tout a compliant solution for internal appraisal management. Unfortunately, this simply is not the case. Automated software can’t manage compliance, the main component of any successful appraisal. Software satisfies only a portion of the solution (and consequently, only a portion of Dodd-Frank), while not at all fulfilling a lender’s safe and sound banking practices.

In reality, the following resources are needed to effectively manage appraisal compliance and processing: appraisal compliance officer/manager, appraisal processing manager, appraisal processor(s) and appraisal management database.

Keep in mind, the staff associated with the appraisal management department cannot be considered loan production staff. A lender will need to prepare the loan production staff to attain the necessary training and qualifications to manage the process—a task that many smaller institutions cannot dedicate resources to.

There is more on the table than Dodd-Frank in today’s appraisal independence in lending. Of the challenges facing the industry, many can be overcome by appropriate allocation of resources in order to ensure compliance as well as fulfillment of safe and sound banking practices. With a trend towards outsourcing, many institutions have been able to take it one step further by addressing these challenges and equipping the institution with a roadmap to loan portfolio stability.

image:renjith krishnan/freedigitalphotos.net

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Joe Petrowsky, NMLS #6869

Right Trac Financial Group, Inc. NMLS #2709

110 Main St.

Manchester, Ct. 06042

Office: 860 647-7701 x116

Fax: 860 647-8940

Cell: 860 836-9294

Email: joe@righttracfg.com

www.righttracfg.com

www.joepetrowsky.com

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Joe Petrowsky does not guarantee nor is in any way responsible for the accuracy of the information provided herein, and provides said information without warranties of any kind, either expressed or implied.

Equal Housing Statement: We are pledged to the letter and spirit of U.S. policy for the achievement of equal housing opportunity throughout the Nation. We encourage and support an affirmative advertising and marketing program in which there are no barriers to obtaining housing becuase of race, color, religion, sex, handicap, familial status, or national origin.

Sharon Parisi
United Real Estate Dallas - Dallas, TX
Dallas Homes

Joe, this is an important and educational post. I am bookmarking it for buyers!

Jul 06, 2012 12:40 AM
Diane Daley
Caron's Gateway Real Estate - Northumberland, NH

Nice when an error can get fixed without a buyer or seller walking that is a great day... Kudos.

Jul 06, 2012 01:11 AM
Joshua Zargari
MJ Decorators Workshop LI staging and home decorating - Lynbrook, NY
MJ Decorators Workshop

Good afternoon Joe.

This is an eye opening article.

Thank you.

Jul 06, 2012 04:31 AM
George Souto
George Souto NMLS #65149 FHA, CHFA, VA Mortgages - Middletown, CT
Your Connecticut Mortgage Expert

Joe, it is not only BROKE it is COMPLETELY OUT OF CONTROL.  In trying to correct a perceived monster, they created a much bigger one.

Jul 06, 2012 08:13 AM
Lisa Von Domek
Lisa Von Domek Team - Dallas, TX
....Experience Isn't Expensive.... It's Priceless!

Hello Joe,

I fight appraisals when warranted, this entire system is a joke and the fact that there is no formal review or process to force a bad appraisal to be corrected is horrendous.  A recent appraisal came up short, and in reviewing it I discovered that (although better comp's were available) for some reason three that were used were 400' larger and 2-story homes (versus the 1-story property)...I think you can guess the outcome.

Realtors can and should talk (professionally) to the appraiser when there are questions or issues as sometimes it is a simple error causing a problem...sometimes, not.

Jul 06, 2012 08:37 AM
Sharon Alters
Coldwell Banker Vanguard Realty - 904-673-2308 - Fleming Island, FL
Realtor - Homes for Sale Fleming Island FL

Joe, this is one of my pet peeves! I agree, it is completely broken - there is no formal process really to appeal an appraisal. There was a time when appraisers were giving ZERO dollar for upgrades in a house, even though their guidelines allow then up to 10% per line item. It's better now, but the banks weren't letting them give any value to upgrades.

Sharon

Jul 06, 2012 01:39 PM
Conrad Allen
Re/Max Professional Associates - Webster, MA
Webster, Ma, Realtor

Hi Joe.  A multiple stage quality control process:(  LMAO.  The HVCC's don't leave enough money for the appraiser let alone a multi stage quality control process.

Jul 06, 2012 08:39 PM
Patricia Feager, MBA, CRS, GRI,MRP
DFW FINE PROPERTIES - Flower Mound, TX
Selling Homes Changing Lives

Hi Joe,

Dodd Frank has got to go! Government needs to stay out and let the process work by the people that are the Real Estate Industry - that's why we have to be licensed, trained and experienced.

Can you imagine what kind of world we would live in if government tried to interfere with our Health Care - oh wait, they are into that too!

Jul 07, 2012 12:12 AM