The rules are changing. Soon the days of borrowers going to a lender or a broker and the local
lender or the broker ordering the appraisal from the appraiser of their
choice will be gone. HUD is now going to require that lenders
require brokers to follow a similar procedure as the conventional
investors (FNMA, FHLMC) do under the HVCC provisions (Home Valuation
Conduct Code) which basically requires that brokers and lenders'
production staff go through the lenders non-production personnel and an
Appraisal Management Companies (AMC) set up by the lenders to order
The thought behind
the move is that if all staff which has an interest in (in other words
is paid on) the closing of the loans is removed from the appraisal
ordering process, then appraisers would be more free to give an
unbiased opinion as they would not be unduly pressured to come back
with a value which makes the loan work. Brokers must contact the
lender who will determine the AMC and then the AMC will contact an
appraiser and will order an appraisal on the borrower's property
(usually chosen on a rotating basis from a list) so that the appraiser
will not be influenced by the production person at the broker's or
lender's office to deliver a set value.
Sounds like it might be a fair quality control measure, right? Well, that is until you actually realize what you just did to all the borrowers who rely on the services.
Firstly, the AMC's are nationwide companies who farm
out the appraisals to local appraisers and the AMC might be located in
New York or Indianapolis and "managing" appraisers in California. Also, the AMC keeps a good portion of the appraisal fee even though
they are not doing any work on the appraisal. Appraisers are
compensated at a much lower rate for their work making it difficult for
experienced appraisers to be able to make a living doing quality
work. Lenders and brokers historically have worked with different
appraisers after years of experience in different markets and a smart
originator will not associate with an appraiser whose values are
constantly cut at review or who does sloppy work and constantly
requires additional follow up.
the new guidelines, the originators now get whoever is assigned by the
AMC and if the work is poor and things are missed, it is like pulling
teeth to get the appraiser to address the deficiencies, let alone get a
timely response. Because the AMC's typically pull names from a
rotation, we have ended up with appraisers who are not familiar with
the markets in which the properties are located, pulling comparable
sales from completely incompatible areas solely because they looked
good on the map.
Now that reverse
mortgages are going to have to follow the same procedures, senior
borrowers will be adversely affected even more. In a recent
conference call we attended, the payment method was not certain with
regard to how the AMC's will accept payment. Brokers and lenders
will not want to front appraisals in any but the most obvious cases
(i.e. where the home is free and clear and the borrowers intend to
proceed with the transaction regardless at what value the property
comes in). Our experience with the AMC's and the appraisers on
the loans where they have been required prior to now leads us to
believe that the appraisers working for the AMC's are definitely
looking to be as conservative as possible, not to work hard to bring in
a solid value.
We are primarily
a reverse mortgage broker and do very few forward mortgages but we have
done 3 loans that required us to use AMC's. All three loans had
problems with the lenders that we had to address; two of the three were
obviously brought in at a low value and on one, the appraiser ignored 3
more recent and closer comparable sales which supported a higher value
than he assigned.
The appraiser also
ignored the fact that the borrower had a permitted addition which did
not show on the appraiser's paperwork (but would obviously be apparent
if the appraiser did his job and taped the home and checked county
records) and simply used the inaccurate numbers and farther comps to
lower the value. The Loan to Value was 76% even at his lower
value so he felt he was ok with his efforts, but what he didn't know is
that there was a very stiff add to the pricing (1.25% in fee) for this
loan program for loan to values over 75%!
This new procedure is going to increase the amount of
time it takes to complete a reverse mortgage loan. In the case of
borrowers in foreclosure, that is not good news. We have saved
multiple borrowers literally the day before or within just days before
their property went to foreclosure auction. It took a monumental
effort on the part of everyone, including the appraiser to do this.
Any time we cannot discuss the appraisals, comps and issues
directly with the appraisers there is a breakdown and going through the
lender and then the lender's third party AMC will add considerably to
the time it takes to process a reverse mortgage.
if the quality we have seen on the forward mortgages is any indication,
then reverse mortgage borrowers may well be in for a rude awakening
with low values, excessive timeframes and strange conditions due to
poor appraisals. Like many originators, we currently keep our
pricing to borrowers well below the HUD allowed maximums.
the added delays and the fallout that is likely to occur, originators
may be forced to rethink their pricing strategies and again, the
borrowers lose. If HVCC meant better quality, it would be hard to
argue against. So far, our experience has been only delays, no
communication, poorer quality work and borrowers have been hurt in the
name of "Quality Control", which has only succeeded in controlling a
worse quality product at a higher price with a longer delivery
What do you think? Please share your comments with us below...
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