Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
Guidance Document Change: Providing guidance to real estate appraisers and AMCs on the use of hybrid appraisals
Previous Comment     Next Comment     Back to List of Comments
6/25/19  1:47 pm
Commenter: Margie Gosser

Modernization or Changes to "Current Appraiser" Procedures
 

Hello, As an appraiser for over 33 years, since the rampant take-over of the AMC-Third Party, I continually am ask 1 time only to perform 1004 Form inspections for far less than the borrower has paid and less than what is fair or reasonable for the appraiser's experience, liability, & time. The AMC shops for the cheapest and results in delays in the ordering process where their goal is retaining the highest percentage-cut of what the Borrower Paid.

There is not Proper Disclosure & Bolded Notification of the break down of the AMC Fee (demand) Percentage. At times, half +- or more of what the borrower paid "for an Appraisal".  The borrower-public: appraisers are to "protect" is included in servicing the mortgage loan. The borrower is NOT aware that the "appraisal" could be a desk-top where the "appraiser never visited their property".  Please consider Re-defining and clarifying this word: Appraisal.  

The AMC demands turn-times generically set where the appraiser must work on Holidays & Weekends. This can result in limited time for proper verification of data used in the report. It is used as a means to generically rate us and limit future work. Appraisers are employees. If we ask for a Proper Fair Fee, the AMC shops for days until & what TRULY IS THE REASON for the highest percentage of "delays" in the assignment process. 

In short, I am no longer "independent" where the actual Fee Schedule the AMC demands is used as a means to compare other appraisers and offer less by using the schedule against us.

How can I the licensed appraiser who must hold "the report- workfile" for 5+-7 years, be the only one licensed where: in Hybrids & Bifi- Reports the Lender gets to choose who does the "A= observation side" of the service. Where currently, there is 'no mandated type of training' for these "observers". Where they must not give "any" opinions & where very important "the appraiser MUST BE ABLE to verify ALL data" for these loan form options. VERIFY for credible results!  The APPRAISER views NOT ONLY the subject property, but the market where the "grid of comparable sales" are used. What about : EXTERNAL obsolescence, condition, quality, and numerous other considerations that WILL NOT HAPPEN with the only one licensed THE Appraiser...sitting behind a desk! How can proper market paired research for ANY variances or differences be "credible" for these TYPES of Forms.  There is NO form specified from Government, Fannie or Freddie; however, the lender makes up their own Form.  How can this protect the PUBLIC? It can't!       

Hybrids & Bifi's: Where, the AMC-Lender OFFER-demand of $50-$75 does NOT provide a sufficient Fee for these type of services when an AMC is used as the Third Party, to remain IN BUSINESS. This will in fact, create the "shortage" of appraisers where current FAKE News indicates there is a shortage. It does seem in the current "test" of these products, NO ONE has considered the fallout.    

The Proposed Threshold of $400k does in no way consider the Current Median Price (@$250k in my area) & this will be HIGHLY concerning when Waivers & Hybrid products are used.  NO ONE has considered the impact. In fact, the News has not even "ask the appraiser" who IS "boots on the ground".  WHO will give the appraiser "a PASS" when these type of loans all over our great country Fail!?    

I will not, as many of my peers will not be able to survive much longer. I have made less each year while business expenses & required licenses remain or rise in costs. There is NO threshold on HOW MUCH of the Borrowers Loan charges for Appraisal Services IS RETAINED by the AMC. The AMC who was suppose to BE the Third Party is NOT hired by the Appraiser???  HOW have they be allowed to TAKE so much of the fee, that THE ONLY UN-Biased LICENSED Person, the appraiser WHO IS a part of the PUBLIC too, is NOW expected to work XXXX times harder for XXXX dollars less AND HAVE THE same IF NOT MORE...liability?   It just simply CAN'T.

AMCs can GO out of business and DO leave 100000000 of appraisers across the country UNPAID because the state bond IS WAY to LOW and way to insufficient. 

Seems like, someone should CARE about "the only ones, the appraiser" where it IS THEIR responsibility through license, education, experience, COMMON sense, NOT BIASED ...the only ones that WILL NOT PROFIT from loans.  WE should be PROTECTED. WE should be treated FAIRLY. 

For 33+ years through the HVCC, through Dodd-Frank, and here we are to this AND STILL ...NO protection.  Is there little wonder WHY we can NO LONGER afford this CAREER?   The FAKE NEWS will surely become REAL, a shortage of appraisers. 

Appreciate your time in considering WHAT YOU ARE GETTING READY TO DO.    

CommentID: 72709