From a recent FHA Mortgagee Letter: Does anyone think that won't be the primary choice of a complaint? If your options are: 1. Inadequate properties ("No, can't argue about that since those comparable sales are just like mine and all sold recently...") 2. Factual or other errors ("No, can't find anything wrong with the facts in the report...") 3. Prohibited Bias ("Perfect, that will show that appraiser they should have made my contract price work!")
🏡Joshua Stephens
5mo
The ROVs highlight two separate but intertwined issues… Although I agree consumers/lenders should have the ability to challenge an appraisal, I think that in order to do so, there should be some ”skin in the game.” Sending an appraiser 20+ comps to sift through, requesting narrative to why each one wasn’t used is a huge waste of time. When this happens, it seems like the lender/consumer is throwing anything at the “wall” to see what “sticks.” Additionally, I am concerned lenders and consumers may file complaints on appraisers for “not making value” and the appraisers have zero recourse for unscrupolous accusations. Reviving a complaint notification from your state licensing board, regardless how legitimate, sends a chill through your being. The fact that an uneducated, untrained, non-professional can file an unsupported complaint without any cause is rediculous. Furthermore, “anonymous” complaints are WACK. It would be great if there was a standardized process for educating appraisers with questionable delevirables, instead of rogue underwriters/reviewers filing complaints with nothing on the line. #soapbox
Craig Gilbert
5mo
We have the disclosures now (for any party in a loan transaction) in CA on precisely where & how to turn in a “biased” appraiser for investigation.
Vice President - Appraisal Manager at InterBank & Certified Residential Appraiser
5moOhh this is going to get ugly. But don’t forget the new ROV process starting the end of August which everyone is supposed to have in place. 1.) The ROV disclosure is to be provided to the consumer at Loan Application (just an FYI) 2.) The ROV policy is to be provided to the consumer again with delivery of the Appraisal Report. 3.) The Borrower/Realtor can initiate ROV requests but must go through the lender and their UW/Appraisal Department before it goes to the appraiser. Agents/Borrowers do not contact the appraiser in regards to ROV requests, they can’t talk about their appraisal as USPAP is administrative law in all states. 4.) The lender is responsible for ensuring the ROV request has relevance before submitting to appraiser. 5.) The ROV will need to explain what they think is wrong with the report and where. The appraiser will have to respond in a revised report as to why the items in the ROV are relevant or not. Now, exactly who can we notify if a lender is not doing this? That is a good question, I guess FHA, FHFA, but will they do something about it is another story.