Did you hear the news? There’s a proposal from the FDIC, Federal Reserve, and others to not require appraisals for some mortgages under $400,000. This is a big deal and I have some thoughts. Actually, Ken Harney in the Chicago Tribune penned a fantastic piece about this today (I was quoted too).
Dude, this will save us money: The idea is to do away with traditional appraisals so consumers can save money and the loan process can speed up. Here’s the thing though. Regarding cost, the appraisal is one of the least expensive elements in a transaction. Of course to be fair the Borrower might pay a much higher fee for the appraisal because of what Appraisal Management Companies (AMCs) charge the consumer. Regarding turn-times, if an appraisal was ordered right away that would speed things up. It also doesn’t help if an AMC offers an absurdly low fee and shops around for an appraiser willing to work for that amount.
A 60% change in a slowing market: It’s troubling to hear a proposal to increase the appraisal threshold from $250,000 to $400,000. This 60% change hurts appraisers, but let’s be real about who it is helping. This is a ploy for banks and big corporations to make money by controlling the valuation process. This rule of course doesn’t necessarily mean appraisals won’t be required in all situations, but the danger is it paves the way. More than anything though this looks like a move in the agenda to usher in an era of “evaluations” (see below).
Systems of checks and balances: Consumers are certainly not being protected here. Why are we diminishing the role of the appraiser, one of the systems of checks and balances for our financial markets? What could possibly go wrong? This seems like very convenient timing for banks too because it helps position them to operate with looser standards as the market is softening.
The people behind the rules: We have nearly 95,000 appraiser credentials across the country, so changing the rules can put lots of people out of business.
Evaluations instead of appraisals: There’s been a big push to introduce “evaluations” in lieu of appraisals. As Ken Harney writes, “Instead of a formal appraisal, these homes would receive an “evaluation” by individuals who have no appraisal licenses or certification and would not be subject to current state regulatory oversight requirements that govern appraisers. The evaluators could be an “independent bank employee” or unnamed “third part(ies).” They would, however, have to be “competent” and possess “knowledge of the market, location and type of real property being valued.”” I’m guessing these “evaluators” will be real estate agents who do BPOs, employees at banks and data firms, and probably some appraisers who need the work at $75-$100 a pop.
Hybrid appraisals: Speaking of changing the appraisal process, it’s worth mentioning there is a hybrid evaluation product where someone else does the inspection part while the appraiser does the value part. I’m not certain if all evaluations would work this way, but here’s the gist. An individual would measure the property, take photos, make notes, and then send everything to the appraiser to do the value part. I really don’t like this idea because it treats value like it’s only crunching numbers at a desk instead of seeing the fuller picture of a property. I want to see the home, walk the parcel, smell the property, observe the street, understand the layout, etc…. instead of relying on someone else’s photos and notes – especially if that person is inexperienced.
But less appraisers is good news: I realize some might be excited to have less appraisers. I get it. But here’s some honest questions. If you work in real estate or you’re purchasing or refinancing a home, what’s going to happen when less experience is infused into the valuation space? Do you think that’s going to help protect consumers? If you’re frustrated now, what are you going to be feeling in the future? Does it bother you the banks are changing the rules to their benefit?
ACTION STEP: If it’s within your power to say something, please speak up right away. Maybe ask your local and state associations to make a statement and put pressure on the FDIC, Federal Reserve, and Trump administration. Thank you for your consideration.
SIGN THE PETITION: There is now a petition, so please sign here to make your voice heard.
I hope that was interesting or helpful.
Questions: What do think of this? Is this a good move? What are any positives and negatives you see? I’d love to hear your take.
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Hey Ryan! This is a powerful post! It is scary to see things moving in this direction. I do believe that the move to slowly eliminate appraisers is going to have terrible consequences not just for our profession, but for the entire housing market. We are the last line of defense in protecting the public in a real estate transaction. Thanks for writing about this very serious situation.
Thank you Jamie. This is a huge issue and I don’t think consumers have any real confidence in the banks. Yet the banks are gaming the system to get rich.
Yes indeed! It is a scary direction to be heading in.
I don’t think consumers KNOW or have a clue what’s going on. That’s the problem. Most people have no clue that this is happening. If they did there would be more of an outcry. See my post/response below about the comparison to NFL games. I think it’s a fair comparison. If that happened, you can guarantee there would be a HUGE outcry by fans. The problem here is that the vast majority of the public have no idea that this is happening.
Part of the issue is we haven’t had a unified voice in our profession. It’s unfortunate. Some of that appears to be changing right now, but it’s something that should have happened many years ago.
Hello Ryan, I could go so many ways it isn’t even funny with this. But can some explain to me why the borrower has to pay $1500 for a title report that excludes almost everything. I find my fee as being the issue with the loan closing. And now that I am started can someone please explain to me why they want the loan process to go faster for people whom typically have no RE experience, why is that we want to rush them through the largest purchase that they will ever make in their lives. This makes absolutely no sense. And further more let me get this right the Federal Reserve thinks this is a good idea. This is the same group that as we speak is going to raise the interest rates to far and push up into a recession. Okay I am going to stop now as I feel my blood pressure increasing. If anyone knows me and wants me to go to DC let me know, it won’t be the first place I have ever been thrown out of .
Ryan, way to go, the RE agents should be concerned as well. I get calls all the time asking for assistance. This should be interesting. Thank goodness my business is about 30% lender work. I guess soon to be lower. But I am okay with that. Guess I will work with people that really do want to know what is going on the in market. It is obvious that the Feds and Bankers couldn’t give a hoot. Well okay Merry Christmas and Happy Holidays. We seem to be heading down the same road as the GM employees. All to increase stock price and bottom line. That should end well.
Thank you Brad.I have also diversified my business into private work for this very reason. Inevitably everything will speed up in the future to create a more efficient process. But one thing that won’t speed up is the human brain and needing some time to process a decision. It can be a real blessing to have that 2-week+ contingency period in order to get inspections done and make decisions.
Thank you for the post Ryan. I’m an appraiser and this is just another move to reduce the need for appraisals and appraisers along with appraisal waivers and alternative valuation products. We live in a time when deregulation has the momentum politically and that probably will not change until the next big problem happens. I only do non-lender work, but I know that for every lender appraisal that is not needed there will be another appraiser competing with me for non-lender work. I am working hard to diversify my business because relying on appraisals for income could be difficult in the near future.
Thanks Gary. You have done a great job. I am in the same boat as I have diversified my business out of lender work. Yet my business is still in appraisals though too, where I know you have really been thinking out of the box with some of the services your companies are offering.
Great post Ryan. I’m concerned about the timing of this announcement when much of the US housing market is nearing a peak. Now is exactly the wrong time to loosen regulations regarding real estate transactions.
Thanks Joe. Yes, this timing seems very ironic. On a somewhat related note I can’t help but think of Fannie Mae’s announcement a few months back that they won’t require the 1004MC any longer. Why would Fannie Mae not want appraisers to fill out this form that helps show more defined data for market trends? I know I sound like a conspiracy theorist here, but there is a real move in several ways for banks and institutions to position themselves to make more money by re-writing the rules.
I agree that banks want the rules loosened because of rising interest rates shrinking the lending market. We’ve seen new rules for a while raising risk for marginal gains. The 1004MC rule change was more of a realization of the inadequacy of the form in my opinion.
The form really is inadequate. I agree there. Why not introduce something better as a replacement then in a time when the market is changing? This form was released 10 years ago. There’s definitely been enough time to make it better.
I agree the elimination of that form is a result of it’s poor design. It works great for a homogenous area but falls apart for rural, diverse and unique markets. They really should have a micro and macro analysis and 2 years.
Thanks Taunya. Yeah, I won’t die on a hill stating Fannie did this to prepare for the coming market. I do have my suspicions and I cannot help but think of ulterior motives here. I completely agree about the form. Well said.
I HAVE A FAR BETTER IDEA, LETS GET RID OF THE AMC’S WHO OVER CHARGE BORROWERS AND UNDER PAY APPRAISERS. MOST ARE EITHER OWNED BY THE BANKS ANYWAY AND THE MOST OF THE REST ARE CORRUPT ANYWAY…..JUST A THOUGHT
Thanks Kathy. The idea of “customary and reasonable” appraisal fees under Dodd-Frank didn’t seem to play out too well in the market in many cases – especially with some AMCs.
Ryan, GET THIS POST OUT THERE!!! More people need to hear the truth! What is happening is just mind blowing to me. How would NFL fans react if the NFL proposed that they are going to play games without any referees? Or, better yet, instead of professional referees we’re going to invite casual fans that sort of know the calls to referee a professional NFL game because they’ll do it for a fraction of the cost of a NFL ref… Sounds like a great idea!!! This stuff gets my blood boiling. Those of us that went through the roller coaster years of 2002-2006-2010-current understand the value and importance of unbiased, objective, independent, impartial opinions in the lending and risk/collateral assessment process. It’s mind boggling to me that these “smart” legislative people just fail over and over to grasp the facts and really understand basic economic principles. 🙁
Thanks Jacob. I appreciate it. I do hope this post travels near and fear. This is happening quietly and needs to be heard. Love the NFL analogy. On a side note I recall the replacement refs years ago when the official ones went on strike (in the past 10 years I think). That was a disaster. Of course refs never get it right 100% of the time, and that’s certainly true of appraisers too. But there was a striking difference between those with skill and those without, and I’d say it’s a better game when skilled refs are allowed to do their thing.
Removing an “independent” appraisal strikes me as a dangerous move. What’s next? Removing title and escrow companies and allowing bank personnel to manage that as well? Utterly ridiculous. It is imperative that we keep the checks and balances in place to protect the consumers, most importantly, but also the many other related service providers that are essential to a real estate transaction.
Preach Alice. Thank you.
Such a good piece Ryan, very well done. We need to start collecting HUD-1s to show the cost of an appraisal related to other costs. Suspect there is a lot of money going to the title company, including document prep fees, and yet not any urge to get rid of that. Which is more important, in particular when title insurance does not cover that much.
Thanks Rachel. I appreciate it. It’s been a struggle in some states through the years to simply disclose the AMC fee vs the appraiser’s fee on the HUD-1. Go figure. Nothing wrong with transparency.
Great points, Ryan! I don’t think consumers understand all of the additional fees in a mortgage transaction. I certainly understand wanting to reduce fees and time processing but the appraisal fee is such a small percentage of the closing costs and the only unbias third party element that protects the consumer. The appraisal is plays such an important part in protecting from fraud or overpaying for properties.
Yep. Thanks Shannon. Over time a mortgage should be more efficient, and frankly appraisals may look different in the future too in light of the advent of big data and such. But let’s not get risky in the market here. Seems short-sighted.
IF ONLY…I DON’T KNOW IF ANYONE ELSE HAS HAD ISSUES WITH TITLE CO NOT GIVING THE HUD-1 AS I AM CONSTANTLY TOLD IT IS CONFIDENTIAL INFORMATION
Funny thing, they think the appraisal is so important that they won’t let trainees do anything and they have been trained, but now they just want to do away with appraisals, how stupid. The scary part is alot of the Realtors are the worst part of the transaction. Many are untrained and do everything wrong, so it is up to the appraiser to correct many of the wrongs that they create. I agree if they want to lower prices, get rid of the AMC’s they add NO value.
Thanks Janet. I appreciate your take.
For any onlookers too, please pitch in your thoughts. It’s okay if you don’t agree with appraisers here too. I’d like to hear from loan officers and real estate agents in particular. So far it’s been a little quiet on that front.
I did have two emails this morning where people said this move is the byproduct of big data and a more digital mortgage experience. I appreciate that take. I think part of that is correct in that real estate is changing right now and we can expect appraisals to look different in the future. Yet a move like this to not require appraisals seems more about the agenda to usher in an era of evaluations instead. Thus using unlicensed individuals instead of those who are already licensed seems very twisted. My hope is that if valuations look different in the future that an opportunity would be available for appraisers to be at the forefront instead of pushed to the side.
Having been a Realtor for the last 18 years, I know what it feels and looks like when there are no checks and balances. The Great recession of 2008 was caused by banks driving the market for more and more fees. They were like crack addicts. Never want to go back to that market!!!
I value the role of the appraiser. I use it often to keep my sellers in check when they want to list there property way above fair market value. It also help buyers understand values before making offers …”what is fair and reasonable.”
The excuse of saving money is complete BS, almost laughable as pointed out in your blog. I hope they are just sending this up as possible “trial balloon”. Appraisers need to take a stand. Maybe NAR should too! I can’t imagine they would seriously consider this. If they want to help the consumer they should do away with the Big Banks monopoly and let smaller regional banks and credit unions get in…. they are closer to the market and the consumer anyway. This would help the consumer more then waiving the appraisal fee. Good grief!
Thank you John. Fantastic commentary. Yeah, there’s something important about a system of checks and balances. We see that in politics and we see that in real estate (and life). Let’s therefore tread carefully.
I do hope this is a “trial balloon” as you say. There is a definitive agenda for pushing more limited “hybrid” appraisal products and “evaluations”. The lobby for that is very strong, so in my mind this looks like one step closer to that reality. Let’s not forget about more appraisal waivers happening too….
This is NOTHING more than a power grab!
Yep. Thanks Gilbert. It’s a power grab being advertised as something to help consumers.
Wow, Ryan, I’m in shock and sorry to hear this! I always thought the appraisal benefitted the banks more than anyone else, so I don’t understand why they would want this to happen. As a house flipper, I always dreaded the appraisal and even some of my colleagues have an “Appraiser Black List” and consider appraisers to be the enemy (not me though)! But I also believe the market is slowly eliminating the real estate agent and soon our services will be obsolete like travel agents. Buying and selling real estate can easily be done online now. I guess in modern times multiple streams of income is the most secure way to go. I wish you and your industry the best and hope you can save your industry!
Thanks Bev. I appreciate your concern very much. I am diversified outside of lender work thankfully, but this still grieves me and I’m not beyond the reach of being affected either. Things are definitely changing in real estate and we have to accept changes when they come. I’ve had lots of conversations today about what appraisals might look like in the future, and they’ll be a whole lot different eventually. Though even if the reporting looks different, I have to think it’s best to retain licensed valuation professionals.
If everyone is doing their job correctly the appraisal rarely holds up loan files, at least in my experience. They might have a year or two back when turn times were often 2 weeks but even then, if all conditions were cleared, 25-30 day closings weren’t an issue. Not sure where this nonsense is coming from that this holds things up. People not involved in real estate or lending?
Thanks Jeremy. I really appreciate your take. Yeah, turn-times were really backed up for a while for many appraisers during the midst of a huge refinance boom in years past. When that ended though, turn-times got back to normal (and fees in some markets even softened back to pre-boom levels). I think maybe the end-goal is here is for a more efficient mortgage process, and I get that. On a side note I hear the new Fannie Mae appraisal form will actually be online too. That’s just hear-say, but I’ve heard from a number of people, and it would not be surprising if that did happen. So on one hand we can see how technology is pushing a different type of appraisal product. Though in this case we can see also the quest for efficiency maybe being placed ahead of what is healthy for the housing market. If we create a system where appraisals aren’t needed, we have to pause and ask if that’s reasonable. What if we start to see non-licensed people delving into value? On a practical note, if that is the case, would the state have jurisdiction over those people? Where is the accountability?
Dangerous and slippery slope. Appraisers are one of the few checks and balances remaining. But years of vilifying appraisers as deal-killers gets us here, especially when borrowers are being charged sometimes double the actual fee the appraiser receives, so they do see the “appraisal fee” as being a significant cost in the deal, despite so much of that fee going to no-value-added AMCs that are often just rent seekers that unnecessarily slow down and muck up the whole process, to the detriment of the consumer.
I predict appraisers will be almost completely sidelined in the near future, replaced by “evaluations” and AVMs where the goal is to make every transaction go through, regardless of whether or not the market value of the property actually supports the loan.
And then when the market turns …
Thank you Alison. I really appreciate it. Times are changing and in some very real senses appraisers are going to have to change with the times.
Thanks for the post and information Ryan. I signed the petition, donated and sent a note to President Trump at whitehouse.gov.
You are so welcome. Way to go Pamela!! Excellent!!
How about updating the 1970s era difficult-to-read residential appraisal forms to something more useful? The standard “URAR” appraisal form is around 4 pages and is cluttered with sometimes 20 pages of “addendums” because this form is so inadequate. Spaces are too small to complete the defined fields, data is duplicated, essential info is left out, etc.
Perhaps if there were proactive action to improve appraisals, reports, and their accuracy, appraisers would have a stronger leg to stand on.
This is not a good move for appraisers, but I believe it is not nearly as bad as the AMC epidemic that appraisers have suffered through. Remember, currently the threshold is currently $250,000. Many appraisers are still appraising homes below this amount, and this would continue under the new rule. What we really need is to eliminate AMCs and provide a clear, easy to read, modern appraisal form that was designed in the computer era.
The argument is that a higher threshold will create a low fee “loan production environment.” AMCs have already done that.
Thanks John. I appreciate your take. New forms are going to be coming out soon-ish I hear, so we’ll see if any of your concerns are addressed. But if appraisers aren’t thoughtful about what goes into the form, then it’s just meaningless. So your point is strong that the quality of work greatly matters here.
You are right that this may not impact some loans, though the bigger agenda is what I’m concerned about. It’s just one more way to push appraisers out of the way to usher in an era of “evaluations”.
Appraisers have already been pushed out of their useful role by AMCs. I know of many appraisers who purposefully seek out the loan amount and then hit that number every time. Why? Because AMCs will take you off their roster if you don’t appraise at the pre-determined number. It’s hard to blame appraisers really, when the choice is between getting paid and going hungry.
So when the appraisal report becomes irrelevant, the logical step is to remove it. Sure, not all appraisers are doing this. But every AMC I have worked with is forcing this to happen.
Are AMCs a bigger percentage of the market than evaluations? They certainly seem like the bigger threat, and appraisers have done nothing to stop them.
It is frustrating, though, when appraisers are forced to do things like visually inspect comparable sales, months after they are sold, often in different condition than the period being analyzed, or else we have an unacceptable work product, but are told someone with little training can sit at a desk and complete a 1 page form in under an hour that replaces us.
This underscores how important it is for appraisers to increase their skillset, tell the truth, and do what USPAP mandates. AMCs could be the middle-man to broker evaluations too. It really depends on how it all plays out. One thing to remember in all of this is technology is changing and it will force appraisers to report in different ways. I get that. Let’s just be sure appraisers have a role.
I will say too that appraisers aren’t forced to “hit the contract” price. There is pressure, but there is still a choice. My advice to anyone struggling with bad clients who put pressure on appraisers? Take a marathon approach and embark on a journey of increasing your skill-set and earning new clients.
Hi Ryan,
I’m super disappointed to hear the educated professional is being replaced. I’m not sure what anyone thinks they are really saving – it’s only a few hundred dollars. In the long run it’s a tradeoff for thousands of dollars in discrepancies (aka gambling). I guess in the internet era and Zillow people are being mislead while nobody notices. I’m not sure what anyone thinks they are gaining. I signed the petition as well. Thanks for speaking on this important topic.
Thank you Renee. I appreciate your comment and support. Thank you sincerely for signing the petition too.
I think that as boom and bust cycles become normalized as they have this sort of thing will be become more common. I don’t think appraisers or real estate agents will be viable jobs anymore.
No longer is there a business cycle, we are in predictable credit manipulated LaLa land with Austrian economists rolling over in their graves watching this display.
Since Bubble 2.0 is clearly starting to burst, you can expect more questions as to the usefulness of appraisers and RE agents. To be clear, I do not support it, and see the value in appraisers, however with unchecked debt fueled bubble mega-cycles like this, it is to be expected.
Thank you. I appreciate your support and your realistic sentiment of course. I gave a presentation two days ago in a real estate office and an agent brought up the appraisal threshold changing. I said this, “I know, some of you might not even like appraisers, so this might seem like welcome news. But guess who’s next? And that’s exactly why I want to ask for your support.” I’d be delighted to see CAR and NAR speak into this issue.
Frankly, in coming time I’m concerned about what lenders will do in the marketplace. There is not much incentive to be less risky if a bailout is an option.
I’m just gonna rattle off some crap without any editing or structure.
When I was a commercial and residential broker both I always thought it was ridiculous how many agents had animus for appraisers. Regarded them as ‘deal killers.’ But agents are notoriously shortsighted. As good as the next deal and in denial of market realities.
Agreed that hacking appraisers will be Crazy Town again with lenders.
Everything Bubble 2.0 deflating will be impactful especially because our country is so divided and battle lines are being drawn. Everything will change which is why I won’t be surprised if RE agents no longer exist in a cycle or two, along with appraisers.
Again, not saying I think it is a sound idea necessarily it’s just that the way everything operates in our society is fundamentally changing. Appraisals will be automated in no time. Why wouldn’t they? I was just at Home Depot in Auburn on 49 (hadn’t been to that location in years) and the entire checkout bank was automated with new computers to interface with. I didn’t see one cashier anywhere.
Agents are next too. No question. Although in fairness, agents have done a terrible job in many ways of selling any sort of real value proposition so society will not care when they become dinosaurs. It is so low barrier to entry and anyone with a pulse and basic middle school level test taking skills can become a licensed salesperson. And once licensed most simply peddle ‘it’s a great time to buy and sell!!!!!’ incessently and don’t take the time to educate themselves at all or study history or basic economics. In other words, they are useless beyond pointing out a nice built-in or commenting on how nice the quartz counters are. Almost no agents understand contracts either and the office manager or an escrow coordinator helps them check boxes. I could go on but you get my point.
All the while buyers and sellers access everything online including comps, valuations, tracking inventory on Realtor.com which trails MLS by 10 minutes, etc.
I don’t think appraisers and realtors should be lumped into the same category. I think appraisers have a critical role and should not be outsourced to AI, whereas the arguments for the relevancy of agents anymore is getting harder. I think I’d take a computer over 95% of RE estate agents. They get in the way and are better off doing nothing. My favorite agent I use a fair amount is one that is humble and well aware of the fact that they do not know much about RE. Just get out of the way and let me close this transaction. Old cocky entitled agent (usually the guys sorry) out of the way, you will never get my business or any of the players I know.
Agents, if you don’t want to become a dinosaur then you must have some value proposition. You can’t just cry when your business as a travel agent becomes obsolete after society stops attaching value to your job. Become relevant and put in some work and provide value, and guess what, your job will always be secure.
When appraisers get the chopping block though I think bad things will happen to the already distorted marketplace where values are completely detached from incomes. Look out below.
Oh dang, this is quite the comment. Strong words, but there is some truth here. I especially liked your statement, ” You can’t just cry when your business as a travel agent becomes obsolete after society stops attaching value to your job. Become relevant and put in some work and provide value, and guess what, your job will always be secure.”
Times are changing. I’m anxious to see how this market over the next 1-2 years unfolds exactly.
I keep reading that the appraisal protects the consumer. In fact the appraisal for a transaction involving a mortgage protects the bank. The intended user is the bank and the intended use is to evaluate the risk of funding the loan. The bank is not concerned with risk because when they fail, the tax payers will be the ones who foot the bill for the bail out. The bank CEO’s and other admin will have already received and spent their bonuses for closing on all the loans. And the consumers who have defaulted on those loans will walk away unscathed.
Thank you. Banks really don’t have much incentive to be conservative here. If they can get bailed out and come out incredibly rich, it’s not a surprise what direction they will lean.
This is partially true but does not tell the whole story. Yes an appraisal for lending purposes identifies the Intended User as the “lender/client”. However the consumer is still on the hook for the loan with their credit on the line and therefore an accurate and well prepared and supported appraisal does in fact protect the consumer from overspending. How would you feel if you bought a home for $500,000 only to find out a year later you can’t sell it for what you bought it for because it really was only worth $400,000? You’d be pretty pissed. I know I would be. And no, you were not the intended user so you can’t sue the appraiser (this is why we are advocating for consumers to engage appraisers directly…). But I’ll tell you right now – having worked in both the Appraisal industry and the Realtor industry, I would MUCH rather have a professional appraisal done for my refinance or purchase rather than some type of evaluation or AVM or CMA or BPO.
I don’t think anyone is saying that the consumer is the intended user and that’s why they’re protected. That’s not the issue. The issue and the facts are that the consumer is in fact protected when professionally trained unbiased, objective, independent, impartial parties objectively research and analyze the collateral and market conditions. Without that the lending process is jeopardized and you run the risk of things such as fraud, over-inflation, loans to individuals/parties that shouldn’t be getting loans…
Thanks Jacob. I appreciate your thoughts.
I think we are also forgetting that appraisers call out any necessary repairs so that we can get those items negotiated into the contract and fixed at the time of sale. Its a slippery slope to get rid of professionals for an automated or partially automated version.
Thanks Renee. Yeah, looking at a property from an appraisal point of view definitely involves a different set of eyes. I’m not saying what an appraiser does at the inspection cannot be learned, but there is something to be said for years of training.