On its own, the recent decision to provide a temporary appraisal waiver for the entire state of North Dakota is mind-boggling for a number of reasons and seemed pre-determined:
- The state has been challenged by the lack of appraisers in rural areas since time began and there are plenty of appraisers in metro areas.
- The inference is that all states with a lot of rural areas should have to have qualified experts come up with valuations.
- There is no verifiable appraisal shortage in the state. In most cases the problem is with AMCs and their business model, unable to pay a fair wage to appraisers covering rural areas.
- FRB – Art Lindo (Chair)
- CFPB – Philip Neary
- FDIC – Marianne Hatheway
- NCUA – Tim Segerson
- OCC – Richard Taft
- FHFA – Robert Witt
- HUD – Bobbi Borland
Only FHFA and HUD voted against the North Dakota Waiver. Those specific agencies deal with appraisers first-hand and understand their role in the risk management process. The remainder are bank regulators or in the case of CFPD, represent consumer interests (and the agency has been gutted over the past several years to reduce its pro-consumer efforts).
In other words, banks are driving the waiver train. They want to remove a pain point from the mortgage process to grow more origination volume. The Federal government has already proved it will be willing to back up the banks if the economy collapses so why not keep pushing for removing of all pain points?
Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.