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HVCC Survey Results:
Appraisers Still Feel Pressure


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April 28, 2010   Vol. 196

Award Winner • Publication Excellence

Editor's Note: Proving Appraisal Adjustments: Part Two - Using Mass Data to Determine Trends, will appear in the next Working RE Online News Edition, May 12.

 

Fighting for HVCC Reform: Mr. Ernst Goes to Washington
by David Brauner, Editor

 

Darwin Ernst, SRA is going to Washington D.C. next month to meet with members of Congress to provide critical input on financial reform legislation which may ultimately have a significant impact on the current Home Valuation Code of Conduct (HVCC): if you're wondering why you should care, read on.  

 

Ernst is going to Washington D.C. as part of the Appraisal Institute's annual Leadership Development Advisory Council (LDAC). This group of practicing appraisers, who are all affiliated with the Appraisal Institute organization, will be discussing legislation currently under consideration and gathering input for Congress to help ensure that meaningful financial reform legislation is crafted. According to Ernst, his team of real estate appraisers, acting as lobbyists on Capitol Hill for the day, will be meeting with Senators Max Baucus, D-Mont, Jon Tester, D-Mont, Amy Klobuchar, D-Minn, Al Frankin, D-Minn, and Representatives Denny Rehberg (R-MT), and Collin Peterson (D-MN).

 

(story continues below)

 

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Ernst, who also sits on the Montana Real Estate Appraisal Board, is taking results from the first Working RE/OREP HVCC Appraiser Talkback Survey with him to share with participants of the Appraisal Institute's meeting. The survey, which has been out for about one year and has just under 5,700 respondents, provides appraiser feedback on the consequences of HVCC.

 

Some key results are: over half of the appraisers working with AMCs report that they continue to feel pressure to "make a deal work" at least some of the time; most  say appraiser selection by AMCs is based solely on the lowest fee much of the time and a majority report feeling consistent pressure from AMCs for low fees and quick turn around and that this pressure adversely effects appraisal quality (for more, read HVCC Survey Results: Appraisers Still Feel Pressure, WorkingRE.com, Current Issue).

In the new Working RE/OREP HVCC Talkback Survey, HVCC: One Year On, 60 percent say appraisal quality has worsened since HVCC. This new survey, which has been out just a week, already has just over 1,000 participants.
You can make your voice heard on HVCC, AMC regulation, customary and reasonable fees and much more by participating (find survey questions and links to both surveys below).
 

(story continues below) 

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"I want to be clear that I am relating my own personal opinions and do not represent the interests of the Appraisal Institute or the Montana Board of Real Estate Appraisers. I personally believe the HVCC has negatively impacted the quality residential appraisers within this nation," says Ernst. "The GSE's requirement to use non-regulated AMCs to provide 'independence' for appraisers is a failed attempt at positive financial reform. The poorly written HVCC has a potential to cause further damage to the public, who are in support of quality financial reform and quality appraisal services. I will share the survey data with my fellow appraisers as a way of encouraging debate regarding beneficial financial reform legislation."

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As reported in Working RE Online News Edition (February 17, 2010), H.R. 4173, which has passed the House, has numerous appraisal provisions including the termination of the HVCC and language in support of appraiser independence and customary and reasonable fees for appraisers. The Senate is taking up its own bill, the Restoring American Financial Stability Act of 2010. However, none of the appraisal provisions from 4173 have made it into the Senate version, according to Bill Garber Director of Government and External Relations, Appraisal Institute. The hope is that the appraisal-related provisions will be added back to the Bill in the House-Senate Conference Committee. This is why it is a critical time for appraisers.

 

"The HVCC is falling very short of protecting the public's trust in my opinion," said Ernst. "Similar to the legislative reform efforts within Title XI, which mandated regulation without providing funding, it appears the GSEs have followed a strong lobby effort and promoted the use of AMCs and BPOs without providing for their regulation."

 

If you completed the HVCC Talkback Survey pat yourself on the back for contributing. If you have not, you can make your voice heard by participating in either survey here (Closed)

 

About the Author

David Brauner is Editor of Working RE magazine and Senior Broker at OREP, a leading provider of E&O Insurance for appraisers, inspectors and other real estate professionals in 49 states (OREP.org). He has covered the appraisal profession for over 16 years. He can be contacted at dbrauner@orep.org or (888) 347-5273. Calif. Insurance Lic. #0C89873.

 



New Survey Questions

1. You have been appraising: 
Less than 5 years, 5 - 10 years, 11 - 20 years, 20 - 30 years, 31 or more years
 

2. You work with appraisal management companies (AMCs):
Always/often, Sometimes, Hardly ever/never
 

3. You have found a sufficient number of AMCs you are comfortable working with and have adjusted to life after HVCC:
Agree, Disagree, HVCC did not affect my business, Not sure/don't know
  

4. You do non-lender, non-AMC work:
Always/often, Sometimes, Hardly ever/never
 

5. You are interested in doing "Appraiser Price Opinions," as long as fees are adequate and they are USPAP compliant:
Agree, Disagree, APO fees are not adequate, APOs are not USPAP compliant, Unsure/don't know
 

6. You refuse work from AMCs when fees are too low, given the scope of the assignment:
Always/often, Sometimes, Hardly ever/never, Fees are typically commensurate for the assignment, Unsure/don't know
 

7. You accept work from AMCs even when fees are too low, given the scope of the assignment:
Always/often, Sometimes, Hardly ever/never, Fees are typically commensurate for the assignment, Unsure/don't know
 

8. You consider having sufficient turn-around time for your assignments to be an important factor in returning competent appraisal work:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know
 

9. You decline assignments from AMCs due to turn-around time requirements that are unreasonable:
Always/often, Sometimes, Hardly ever/never, AMC turn around requirements are typically reasonable.
 

10. You accept assignments from AMCs with unreasonable turn-around time requirements and take the extra time required to do competent appraisal work anyway:
Always/often, Sometimes, Hardly ever/never, Turn around requirements are typically reasonable, Unsure/don't know

 

11. Appraisal quality suffers on AMC assignments you complete due to inadequate turn-around time:
Always/often, Sometimes, Hardly ever/never, Don't accept assignments with inadequate turn times, Turn around requirements are typically reasonable
 

12. Since HVCC, you've seen appraisal quality in general:
Improve, Worsen, Stay about the same, Unsure/don't know
 

13. Since HVCC, you've seen the cost of appraisal services paid by consumers:
Increase, Decrease, Stay the same, Unsure/don't know
 

14. Since HVCC, your appraisal-related income has:
Increased, Decreased, Stayed about the same, Unsure/don't know
 

15. You believe the decline in your appraisal income is mostly attributable to HVCC:
Agree, Disagree, Unsure/don't know, No decline in income
 

16. You are in favor of terminating HVCC:
Agree, Disagree, Unsure/don't know
 

17. You are in favor of AMC regulation:
Agree, Disagree, Unsure/don't know
 

18. You believe AMCs can regulate themselves:
Agree, Disagree, Unsure/don't know
 

19. You believe accurate and professionally prepared appraisals are vital to the health of the real estate industry/U.S. economy/home buyers/tax payers:
Agree, Disagree, Unsure/don't know
 

20. You believe that lenders believe that an accurate and professionally prepared appraisal is vital:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know
 

21. You believe that AMC fees should be paid by the lender or other entity that chooses to use AMC services, rather than taken from appraisal fees:
Agree, Disagree, Unsure/don't know
 

22. You believe refusing to work for unrealistically low appraisal fees could be an effective strategy for raising fees back up to pre-HVCC levels:
Agree, Disagree, Unsure/don't know, Appraisal fees are not lower since HVCC
 

23. You believe a national appraisal "boycott" could be an effective strategy for calling attention to and changing current industry conditions that you consider unfavorable to appraisers:
Agree, Disagree, Unsure/don't know, Current industry conditions are not unfavorable
 

24. You would join and contribute financially to an appraisal "trade group" to advocate for appraiser interests:
Agree, Disagree, Unsure/don't know
  

25. You have trouble getting paid by AMCs:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't accept AMC work
 

26. AMC staff are generally competent:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't accept AMC work
 

27. It appears that AMC staff you interact with are located offshore:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't accept AMC work
 

28. You feel pressure from AMCs "to make a deal work":  
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't accept AMC work
 

29. Since HVCC, your appraisal fees when working with AMCs have:
Increased, Decreased, Stayed about the same, Unsure/don't know, Don't accept AMC work
 

30. Low fees are the main criteria for your receiving appraisal assignments from AMCs:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't apply for AMC work
 

31. AMCs consider your qualifications and/or the quality of your work product when choosing you for an assignment:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't apply for AMC work
 

32. You believe that in your market most appraisers/lenders and other interested parties know (about) what a "customary and reasonable fee" (CRF) is for a particular assignment:
Agree, Disagree, Unsure/don't know
 

33. You are receiving what you consider to be CRFs from AMCs for appraisal assignments:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't accept AMC work
 

34. You believe that delivering a consistently reliable appraisal product is dependent on being compensated for CRFs:
Agree, Disagree, Unsure/don't know
 

35. Since new FHA guidelines requiring appraisers be paid CRF, you have requested and received CRFs on FHA assignments:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't do FHA assignments
 

36. Since new FHA guidelines requiring appraisers be paid CRFs, you have requested CRFs and have not received them or lost assignments:
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't do FHA assignments
 

37. Things have improved for you since HVCC was implemented:
Agree, Disagree, Unsure/don't know
 

38. Things have improved for consumers since HVCC was implemented:
Agree, Disagree, Unsure/don't know
 

39. Things have improved for the appraisal profession since HVCC was implemented:
Agree, Disagree, Unsure/don't know
 

40. Things have improved for lenders/AMCs since HVCC was implemented:
Agree, Disagree, Unsure/don't know
 

41. You believe no one is effectively advocating for appraiser interests:
Agree, Disagree, Unsure/don't know
 

42. Mortgage brokers should be licensed and regulated like appraisers:
Agree, Disagree, Unsure/don't know
 

43. Mortgage brokers should be allowed to order appraisals directly if licensed and regulated:
Agree, Disagree, Unsure/don't know
 

44. You are experiencing less pressure today to alter your appraisal reports, for any reason, than you did before HVCC was implemented:
Agree, Disagree, Unsure/don't know
 

45. Your appraisal reports are more accurate, complete and free of outside influence today than before HVCC:
Agree, Disagree, Unsure/don't know
 

46. You have been "dropped" from an AMC roster for not meeting conditions placed on you that you felt were not in the best interests of an accurate appraisal: 
Always/often, Sometimes, Hardly ever/never, Unsure/don't know, Don't work with AMCs
 

47. You are in favor of VA-style appraisal panels for all conventional and FHA mortgage lending assignments:
Agree, Disagree, Unsure/don't know
 

48. You believe the banking regulators have been doing an acceptable job in enforcing existing banking regulations that pertain to the use of appraisals at the direct lenders:
Agree, Disagree, Unsure/don't know
 

49. You believe that some of the misconduct that occurs in the engagement and use of appraisals would decline if the government regulators did a better job at enforcing existing regulations:
Agree, Disagree, Unsure/don't know
 

50. E&O Insurance:
You purchase your E&O insurance from OREP/David Brauner Insurance Services,

You purchase your E&O insurance from someone other than OREP, You don't purchase your own E&O but are covered under someone else's policy, You are not covered under any policy, You are covered but would rather not say where
 

51. Please offer any questions we missed or comments you'd like to make.

 

 

New: Comment on this story at Working RE's Appraiser Talkback blog.

 

 

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