Appraisers' Free Forum

While Trace Richardson doesn't appear to like the NAR Presidents letter to Freddie Mac & Fannie Mae...I sure do.

http://brokerscience.com/legal/hvcc/nar ... lord-hvcc/

There is concern that GSEs will increase their reliance on automated valuation. While this would appear to address appraiser influence in a transparent way, a deeper look at automated valuations generally reveals they are not able to consider qualitative factors with the same level of reliability that professional licensed and certified appraisers produce.

True enough, but he completely missed the main point about AVM's. That is that they are not regulated. If someone wants to manipulate one, it is not even illegal. Because they don't have to meet the same requirements an appraiser does, and there is no oversight to prevent manipulation, they should simply be illegal under the current paradigm.

Now, if we enter a new paradigm, where lenders and investors are held responsible for their actions, where the government's role is to level the playing field and not to put more and more bureaucracy upon appraisers, then I would be quite confident to go head to head with AVM's... win or lose. In a true free-market situation, I would be happy to retire if AVM's proved to be better than appraisal. Under the current paradigm, AVM's should either be required to meet USPAP or else should be illegal for loan purposes.

While this letter is some better than the mishmash sent in by TAF, I am still not impressed.

One of the items I find truly interesting is the continued use of the language "appraiser & employee" being continually put to use throught the letter. Is someone trying to say that when you sign a Contract with the Lender that no matter how many times they state your Not an Employee, that just maybe it means you are an employee without any benefits ?? Wonder how the IRS would detemine the hours of employment with a Lender not being required to pay the industry standards

Steve, I agree, but also feel very strongly that AVM's are (in your words) a manipulative piece of machinery and therefore, illegal under the guidelines that Congress and GSE's have already put in place. Couple that with a Lenders % ownership in any of the AMC's and you have one brutal combination to decieve the Public.

We have entered into a phase of the most highly regulated profession on the planet, and yet we are offered crumbs for payment and knowledge of all those regulations. Can anyone tell me what; "a timely payment is" There's an awful large quantity of americana language being strewn about, with only the closing of minimal gaps.

Steve Owen wrote:

True enough, but he completely missed the main point about AVM's. That is that they are not regulated. If someone wants to manipulate one, it is not even illegal. Because they don't have to meet the same requirements an appraiser does, and there is no oversight to prevent manipulation, they should simply be illegal under the current paradigm.

Excellent point Steve...you want to write him...or should I?

I think you should do it, Mako. I have a tendency to really tick people like that off.

Or, better yet. Post it here and we can all plaigerize it and each write to him.

I agree with you Mako - the letter, as a whole, makes since, but as Steve and Jay said, there's a mishmash of words and (my point) ideas and he doesn't go far enough to address the full concerns - there's needs to be a melding of all of the responses to all the agencies/organizations into one coherent letter.

Otis wrote:I agree with you Mako - the letter, as a whole, makes since, but as Steve and Jay said, there's a mishmash of words and (my point) ideas and he doesn't go far enough to address the full concerns - there's needs to be a melding of all of the responses to all the agencies/organizations into one coherent letter.

We should pool our thoughts & fire off a joint letter like Steve suggested.

Mako wrote:

Otis wrote:I agree with you Mako - the letter, as a whole, makes since, but as Steve and Jay said, there's a mishmash of words and (my point) ideas and he doesn't go far enough to address the full concerns - there's needs to be a melding of all of the responses to all the agencies/organizations into one coherent letter.

We should pool our thoughts & fire off a joint letter like Steve suggested.

I think you know me well enough to know that I'll always add my 2 cents worth and sign my name to it.

Otis wrote:

Mako wrote:

Otis wrote:I agree with you Mako - the letter, as a whole, makes since, but as Steve and Jay said, there's a mishmash of words and (my point) ideas and he doesn't go far enough to address the full concerns - there's needs to be a melding of all of the responses to all the agencies/organizations into one coherent letter.

We should pool our thoughts & fire off a joint letter like Steve suggested.

I think you know me well enough to know that I'll always add my 2 cents worth and sign my name to it.

I'm not sure how much time (if any) remains?

I have a rather busy schedule the next couple days, but if you know how much time I have I'll try to get started.