Sandra has been an appraiser for the past 15 years, and primarily services the Boston metropolitan area. She decided to enter this field of work when she made a career change after gaining custody of her 2 grandsons. Over the years Sandra has worked through fluctuations in her market, and has seen the changes that have come as a result. Recently, the shortage of inventory in the Boston market has led to an increase in sale prices as bidding wars have driven prices up over the appraised value. In her spare time Sandra enjoys painting and writing, but has remained busy with work in her market. According to Sandra, the key to success as an appraiser is patience. The educational requirements of becoming an appraiser and trainee experience needed is a long process, and patience is essential.
Boston, Massachusetts Market
Sales prices reached new heights in January 2017 for the Boston metropolitan area as demand continues to outweigh supply. The average price for a single-family home increased 7% statewide to $342,500 compared to January of last year, as inventory remained low (The Warren Group). According to The Wall Street Journal, the median sales price for the Boston Market rose from $685,000 in 2015 to $791,000, while rent in the neighborhoods surrounding Fenway Park increased 2.5%. Though inventory is being added to the market, there is a shortage of affordable housing for middle and low income buyers. According to Boston Agent Magazine 80% of the new construction being added to the market is housing, but primarily in the form of luxury apartments and condos. This paired with bidding wars has driven prices up and out of reach for many low-income buyers.
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Your appraisal management software isn’t cutting it–and neither is your appraisal management company’s.
I want to dispel a common misconception. Despite what you hear from the appraisal segment’s technology vendors, appraisal management software won’t keep you compliant. Period, full stop. If you don’t believe me, ask your technology vendor. The truth is, appraisal management technologies can be great tools for automating processes, but compliance is about more than automation. True compliance takes an expert.
As everyone in the mortgage industry is aware, the appraisal process has changed a lot over the past few years. In the most recent news, we have the Consumer Financial Protection Bureau’s third-party oversight requirements. This is a big concern for lenders. The big focus is on the fact that it’s now the lender’s case to prove that its vendors are in compliance. But that’s the only the beginning. Lenders must also be able to prove that their processes (a) use proven predictable methods, (b) can identify issues, and (c) proactively prevent those issues from happening again.
Thanks not only to the CFPB, but also to the Dodd-Frank Act, Fannie Mae’s appraisal independence requirements and the Uniform Collateral Data Portal, not to mention numerous state and federal regulations, there is simply no way for lenders–or AMCs–to get around having a dedicated program for ensuring a compliant appraisal transaction.
Some of you may be thinking that you’ve been doing just fine with your appraisal management software. While anything is possible, it’s more likely that the reason lenders are “doing just fine” is simply because they haven’t been through an audit that indicates otherwise. Yet.
It’s easy to get tempted into believing that it’ll be easy to manage the appraisal process yourself, especially now that appraisal management technology vendors are offering their systems as a Software as a Service type, where you can buy software off the shelf and implement it quickly.
The idea is that if you take the appraisal process internally, you will have a better overall appraisal process, while still maintaining some control. But this is overlooking one very important detail: a strong appraisal process requires experts, not just someone who manages technology. Generally speaking, a self-managed appraisal process is not ideal, nor should it be looked at as a long-term option.
Are there are exceptions to the rule? Yes. However, I don’t know if I’ve ever seen one. I’ve spoken with hundreds of lenders and banks–both customers and non-customers–and I’ve never heard of a self-managed appraisal process working long-term. Every lender we deal with, that has tried to manage the process on its own, has ended up outsourcing to an appraisal management company. The reason is simple: it’s more effective, efficient and compliant. Those are their words, not mine.
The reality is that no one–not even an appraisal management company–is capable of being compliant with software alone. Thinking that an appraisal management software will make you compliant is like expecting Microsoft Word to make you a Pulitzer prize-winning author. Microsoft Word can give you the vehicle to convey your story, but it takes a lot of skill and dedication to write well enough to win the Pulitzer, just as it takes a lot of skill and dedication to be compliant with all appraisal regulations.
If lenders expect to be 100 percent compliant, they’ll need a serious compliance program that includes quality control procedures; internal audit procedures; an internal appraisal and valuation audit system; and a host of compliance systems that keep close tabs on potential customary and reasonable fee issues, quality issues, USPAP violations and appraisal fraud. If you’re missing any one of these ingredients, your system is not going to cut it.
There’s also the issue of appraiser independence. The guidelines state that lenders must establish “absolute lines of independence.” That “absolute” part can mean the difference between smooth sailing and a costly compliance violation. The practicality of a small regional lender or even a midsize national lender establishing “absolute lines of independence” while keeping their appraisal process in house is not realistic.
To be 100 percent compliant with this regulation, the lender would have to set up an entirely new office with a manager, staff appraisers and processors. Most mortgage companies that manage their appraisals in-house are not nearly as equipped or trained as the code requires and typically end up rushing processors into ordering appraisals.
If you’re wondering why this hasn’t been much of an issue lately, it’s because most lenders have not gone through audits with FHA, Office of Thrift Supervision and investors. When this does happen, how are they going to prove that they have maintained “absolute lines of independence,” when the appraisal department is in the same office as the processors and production staff, who are interested parties?
Using an independent third party to manage appraisals provides an extra layer of protection against collusion, which in turn increases investor confidence. There are also the benefits of reduced cost, and enhanced productivity among processors and loan staff, who can stop being concerned with the appraisal process and start focusing on higher yield activities.
There’s no way around it. When appraisal services are handled in-house, overhead costs get higher when production increases, but when volume dips, layoffs become inevitable–after a period of covering the costs of being overstaffed, of course. If volume spikes again, companies are then forced to rehire staff. It’s easy, especially when there’s a revolving staff door, to fall into the trap of quickly assigning the appraisals rather than taking the time to have them done right. Most appraisal companies, on the other hand, have economies of scale, which allow more orders to be done faster and more efficiently than any in-house process.
There’s no excuse for risking these compliance violations, particularly when shifting the appraisal process to an independent third party is usually free to lenders or at least at a heavily reduced rate.
Outsourcing the appraisal process brings consistency to your quality levels, turnaround times and overall costs, regardless of volume. Conflicts of interest will vanish and variable costs will turn into profits. Your third-party appraisal management company can answer any investor questions, just as it can take care of any errors, should they occur.
Adopting a truly independent appraisal process helps ensure long-term success, allows for future growth and makes it easy to maintain positive relationships with investors. That’s something that an appraisal technology just can’t do.