- Stop out of control UNDERWRITERS.
Who are
these people (Underwriters) that tell me to take "Hialeah"
off the appraisal and change it to "Miami"?
If the
appraiser doesn't make the change, the underwriter will oftentimes BLACKLIST
the appraiser. However, should the appraiser execute said
change, then the appraiser should be expected to be chastised by the division
that regulates their license, because the job is NOT in MIAMI,
if it is in Hialeah)
- (Appraisals MUST be accurate - PERIOD).
Underwriters
day after day make unreasonable requests to appraisers that will in fact cause
the appraiser themselves to be in violation of the law, should the appraiser
comply with such erroneous requests.
We are
the appraisers, and the underwriters are not. If an underwriter catches what they
feel may be a typo, or a math mistake, then the appraiser should be consulted
to remedy such error(s).
Proposed Petition
We hereby implore the US Congress to pass a bill that requires
Bank/Lender Underwriters to be licensed for the following reasons.
Underwriter's
erroneous requests MUST be brought to an end, as they are oftentimes in
non-compliance with USPAP, and common sense.
Underwriters,
should (must) be licensed and take mandatory educational class-work to be
knowledgeable regarding the job they are hired to do.
Underwriters
MUST convey any desired change in writing directly to an appraiser, and must be
held accountable by a licensing board for any adverse actions they demand from
appraisers.
Underwriters presently do tell appraisers to change
adjustments. This practice MUST be stopped, as they oftentimes do this to force
the appraiser to "make their number" under threat of being blacklisted or
deprived of further business from their company or under retribution from any
number of sources including licensing agencies and use of malicious review
practices.
Underwriters should inspect the work of the appraiser, but
should have no right to demand any change of adjustments from an appraiser or
demand a change that dictates the valuation outcome.
Underwriters
oftentimes tell appraisers to change a comparable (More often than not to get
the appraiser to "Make their numbers"). If an appraiser used *questionable comparable sales, then
the underwriters sole recourse should be to convey in writing, anything
that they believe to be inaccurate to the appraiser. If the appraisers choice
of comparable sales is incorrect, then the Underwriters sole recourse should be
to turn the appraisal over to a competent and licensed reviewer after the
appraiser has been queried by said underwriter. If fraud is in question, the
appropriate licensing authorities exist to remedy such malfeasance.
Underwriters
oftentimes demand that appraisers overlook property deficiencies to get their
loans closed; ie, don't make mention of that hole in the roof, no one will
notice, OR, do not make mention that there is an illegal non-conforming
un-permitted addition. Underwriters do this so they can get that deal closed,
and sell the bad mortgage paper to a 3rd party lender who gets stuck
with the bad loan long after the underwriters employer has made their
commissions.
**Underwriters should have No
Authority to DEMAND that a Supervising appraiser personally inspect the
property (which they do regularly) in violation of USPAP. Certified Appraisers employ apprentice
appraisers (As Real Estate Brokers employ RE Salesperson's) to measure, and
photograph sales comparables on their behalf, which is why USPAP, does NOT
require an appraiser to personally inspect the property, but only requires the
supervisor to certify that the trainee/apprentice's competence to perform the
duties he/she has done.
Every
state in the US allows apprentice/trainee appraisers to do field work, on
behalf of their state certified appraiser employers, who run an office, research
data, train their personnel, review reports once written up, and handle a
multitude of daily decision making processes.
Other
Non-USPAP dictated and burdensome, malicious, or capricious standards should
not be imposed on the private sector (Independent fee appraisers).
Accordingly, we implore the US
congress to pass a bill
that requires Bank/Lender Underwriters to be licensed for the reasons that have
been cited above.
*Demanding
use of bad (questionable) comparables such as sales that are far
away (to "make the number"), when alternative sales were available nearby,
unless and excepting, unusual property characteristics were inherent, wherein,
the subject was much larger in square footage then the nearby comps, or perhaps
the lot size was considerably larger than the neighborhood predominance of
sales. Prudent judgment should be exercised to ascertain that the comparables
chosen properly reflect the nature and the attributes of the property being
appraised. Waterfront properties oftentimes require an expanded search area.
Appraisals are brain puzzles that necessitate looking at elements of
commonality, and elements of differentiation, and making logical sense of such
similarities, and dissimilarities to derive supported reasonable conclusions of
value.
** A State Certified Appraiser who hires
apprentice/trainees fosters growth in the appraisal industry by allowing others
to learn the trade. If State Certified appraisers are forced to personally
inspect each and every property, then there is absolutely no reason for them to
hire and pay for apprentice/assistant/trainee appraisers. A State Certified
appraiser cannot be expected to drive 50 miles in one direction for a 9 am
inspection, then, another 50 miles in another direction, for a 10 am appointment.
It is physically impossible. If they are demanded to do so, then there will be
and can be no growth for future appraisers to learn the trade. A supervisory
appraiser should train a person to be competent for the responsibilities
assigned; ie, measuring, photographing, and in due time learning the adjustment
processes, and the profession.
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