New Appraisal Guidelines Require Support - Not Opinions

Written by Posted On Tuesday, 24 February 2015 13:05

While you slept, the appraisal industry had yet another "check" placed upon it: Collateral Underwriting. Weeks into it appraisers are adjusting, but the warnings are clear; appraisers must have justification for everything in the report. Opinions? Fuggettaboutit - did you agents and sellers hear that?

Regulations state that appraisal adjustments cannot be based upon an appraiser’s opinion. According to federal and state law, adjustments must be based on support and evidence - proof if you will, and an appraiser’s opinion is not considered to be “support.” Many appraisers have failed to support their adjustments and as a result have had their licenses revoked, penalties assessed and lawsuits lost, all because the they failed to understand a single but important requirement. - Richard Hagar, SRAappraisal adjustments

So what's the impact on home buyers and sellers AND agents? It's pretty simple and the basic tenant hasn't changed - provide tangible data to support value and adjustment positions. What has changed, is the noose that's even tighter on appraisers. Fannie Mae defines Collateral Underwriting as:

Collateral Underwriter (CU) is a proprietary model-driven tool developed by Fannie Mae that provides an automated appraisal risk assessment to support proactive management of appraisal quality. Fannie Mae will make CU available in 2015 to provide transparency and help lenders more effectively and efficiently identify issues with appraisals.

In case you missed it, reread the first sentence and note the word "automated". The marble mouthed government speak is best said as "appraisals will be reviewed by software to validate adjustments and comparable selection".  Boil it down even further, most understand a "zestimate" and most are also annoyed when they complete one on their home. A zestimate is an AVM - defined as:

Automated valuation model (AVM) is the name given to a service that can provide real estate property valuations using mathematical modelling combined with a database. Most AVMs calculate a property's value at a specific point in time by analyzing values of comparable properties.

Right. In simple terms, it's a computer program that "analyzes" data to arrive at an estimated market value. There are obvious fundamental flaws using computers for this - real estate is perhaps the most unique entity in the world, no two parcels or homes are alike and conditions behind a sale are never the same.

So if you as a seller or your agent feel that changing the cabinet pulls adds $7500 or replacing the gold "brass look" '88 bathroom strip light adds $2000, bring something to support that. That condo on the 10th floor is worth $75000 more than the same exact units on the 5th and 6th floor? Support it.

The idea that "checks" are going to be made by computer programs is completely asinine - the unique nature of real estate precludes this type of blanket research. However, the appraisal organizations allowed this to occur and this has been in motion for years. Collateral Underwriting involves more than this but the end result is clear: an appraiser’s opinion, agent's opinion or seller's opinion is not considered to be “support".


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Hank Miller, SRA

Hank Miller is an Associate Broker & Certified Appraiser in the north metro Atlanta area. Since 1989, real estate has been his full time profession. Hank´s clients benefit from his appraisal and sales experience; they act upon data, not baseless opinions. He is an outspoken critic of the lax standards in the agent community.

Hank remains an active certified appraiser and completes specialty work for FNMA, lenders and attorneys. He is a well-known blogger and continues to guest write for multiple industry publications as well as national outlets like the WSJ, NYT, RE Magazine, USA Today and others. He is a regular on public Q&A sites on Zillow, Trulia and many others.

Hank consistently ranks in the top 1% of all agents in the metro Atlanta area. He runs the Hank Miller Team and is known as much for his ability as he is for his opinions. He is especially outspoken about the lack of professional standards and expectations in the real estate industry.

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