Author: admin

Fannie Mae has found significant inaccuracies in appraisals with Collateral Underwriter® (CU) scores of 2.5 and lower.

“More than half of the lenders cited no appraisal findings in their QC reviews on loans where Fannie Mae cited appraisal findings. Fannie Mae found numerous examples of data integrity issues on appraisals with CU scores under 2.5.”

Fannie Mae “Quality Insider” Newsletter

This underscores the critical need for a proactive approach in appraisal review processes, both pre- and post-closing. Accurately identifying and mitigating risks is paramount for maintaining loan quality and ensuring compliance, and that means moving beyond the perceived security of low CU scores.

The Illusion of Security in Low CU Score Appraisals

Low CU scores, while generally indicative of lower perceived risk, do not guarantee the absence of significant appraisal inaccuracies. Such hidden discrepancies, particularly in property condition and quality ratings, pose considerable compliance challenges and financial risks for lenders. Fannie Mae went so far as to include a reminder in the above newsletter that “rep and warrant relief is only achieved on an appraisal with a sub-2.5 score if the subject is accurately described.”

Pre-Closing Appraisal Reviews: A Preventative Strategy

Effective risk management in the lending process begins with rigorous pre-closing appraisal reviews. This preventative strategy involves a detailed examination of appraisal reports for signs of data inconsistency or inaccuracies, ensuring that every aspect of the appraisal accurately reflects the property’s condition and market value. Implementing thorough pre-closing appraisal reviews helps identify potential issues early, mitigating risks before they affect the loan’s integrity.

The Value of AMC Partnerships

Partnering with an Appraisal Management Company (AMC) like Equity Valuation Partners (EVP) offers lenders a comprehensive approach to enhancing appraisal accuracy and compliance. AMCs provide expertise, advanced analytical tools, and a deep understanding of regulatory requirements, supporting lenders in the complex appraisal review process. By leveraging the services of an AMC, lenders benefit from a more nuanced and thorough appraisal review, streamlining the entire process, reducing delays, and improving overall loan quality.

Post-Closing Quality Control

After closing, a comprehensive approach to quality control remains vital. Lenders must rigorously evaluate the quality of appraisals and property data, ensuring all parties – including appraisers and data collectors – meet high standards of accuracy and compliance. Any discrepancies or defects with the potential to affect loan eligibility or property condition discovered post-closing must be reported to Fannie Mae via Loan Quality Connect. Additionally, lenders are tasked with maintaining quality control records for at least three years and subjecting these records to independent audits to confirm adherence to quality control protocols.

Conclusion

Recognizing the hidden risks in appraisals is essential for lenders aiming to ensure loan quality and compliance. A proactive, detailed appraisal review process is crucial. Partnering with an AMC provides lenders with the necessary tools and expertise to accurately identify and address appraisal-related discrepancies before closing, limiting the number of post-closing issues. Through such partnerships, lenders can navigate the complexities of the appraisal process with confidence, safeguarding against potential risks and ensuring a secure lending process.

As the lending landscape shifts beneath our feet, so too must our understanding of risk.

While credit risk has traditionally taken center stage, the evolving landscape of the lending industry necessitates a more balanced approach. Namely, collateral risk needs a seat a little closer to the head of the table.

While credit scores, debt-to-income ratios, and other financial metrics are vital, they are not the sole determinants of a loan’s risk profile. Relying solely on these factors can lead to an incomplete risk assessment, particularly in an industry that is increasingly complex.

Why Collateral Risk Matters

When we say the industry is increasingly complex and the landscape is evolving, we’re referring to things like:

1. Regulatory Changes: New regulations may require more stringent evaluations of collateral, affecting how loans are underwritten and approved.
2. Economic Fluctuations: In a high-interest-rate environment, property values can be volatile. This makes the assessment of collateral risk more critical as fluctuations can impact the loan-to-value ratio.
3. Technological Advances: The rise of automated valuation models and other tech-driven appraisal methods can change how collateral is assessed, making it more important to manage this aspect carefully.
4. Market Trends: Shifts in consumer behavior, like the move towards remote work, can affect property values in certain areas, thereby affecting collateral risk.
5. Alternative Valuation Methods: With the industry gradually moving from traditional appraisals to more comprehensive valuation management, there’s a broader range of methodologies to consider when evaluating collateral risk.
6. Competitive Pressures: As lenders look for ways to differentiate themselves in a crowded market, a more nuanced approach to risk assessment, including collateral risk, can be a competitive advantage.
7. Risk Management Practices: As financial institutions become more sophisticated in their risk management practices, there’s a growing understanding that a more holistic view of both credit and collateral risk is necessary for long-term sustainability.

Given these continually evolving factors, a comprehensive risk assessment must include an increased focus on collateral risk.

The Role of Valuation Management in Collateral Risk

In this context, the term “valuation management” is a more appropriate descriptor than the traditional “appraisal management.”

This is particularly important because a fundamental aspect of balancing credit and collateral risk is the ability to match each loan’s credit risk profile with the appropriate type of valuation or valuation product.

For instance, if a transaction has a low credit risk profile and is under the de minimis loan amount, an evaluation (at most) is probably more appropriate than a full appraisal. Similarly, a loan under the de minimis with a high credit risk profile may still require a full appraisal.

By tailoring the valuation process in this manner, loan policy can not only better reflect the total risk of a given loan, it can also contribute to significant cost savings for the lender and, by extension, their borrowers. By avoiding expensive valuations for lower-risk loans, both time and financial resources can be conserved. This is particularly crucial in a high-interest-rate environment where lenders and borrowers alike are increasingly cost-conscious.

How Equity Valuation Partners Addresses Both Risks

What lenders need, therefore, is an AMC partner who not only understands this balancing act, but is both willing and able to facilitate it. That means offering the full array of valuation products and crafting an intelligent valuation management solution that matches each client’s loan policy and credit culture.

That’s the future of valuation management. That’s EVP.

Appraisal management needs a paradigm shift.

The economy, regulators, and technological advances demand it.

Interest rates remain high, and that means mortgage applications remain low. Yet as revenue from loans is decreasing, regulatory scrutiny is increasing. The bottom line? Whether it’s a renewed focus on Appraiser Independence Requirements (AIR) or a new focus on bias in appraisals and AVMs, the cost of compliance is going up.

So how can lenders ensure they have cost-effective, reliable, and compliant appraisal management?

First, a common misconception needs to be dispelled – that in-house valuation management is cost-effective. When calculating the per-order cost, even if the direct staffing costs are accounted for, what’s almost always left out are things like the need for ongoing training, software licenses, and staying current on regulatory changes.

Moreover, in-house appraisal management isn’t scalable, meaning lenders don’t have the ability to quickly adapt to market fluctuations. This leads to overstaffing during slow periods and frantic hiring scrambles to meet demand during busy times. Either scenario is financially and emotionally draining.

So the short answer is “work with an AMC.”

But simply deciding to work with an AMC isn’t the full solution. The one-size-fits-all approach of many firms is not only ineffective but also fraught with risks. What’s needed is a paradigm shift towards a more nuanced and effective approach that takes advantage of technology to align with both the industry’s evolving demands and individual lenders’ needs, while keeping the end user – the borrower – happy.

In short, what’s needed is intelligent valuation management that makes every valuation personal. Behind every order, every loan, is a person or a family with unique needs and aspirations. When that’s the focus, technology is sought out or developed to make reliability and quality control integral parts of the process.

In a world where most AMCs treat orders as mere numbers, the value of personalized service cannot be overstated. When you call, you need someone to answer. When you have a valuation need, you want it handled with precision and care.

For lenders, the choice is clear: personalized, intelligent valuation management is not just an option; it’s an imperative. And you need a partner that’s big enough to get the job done, but small enough to get it done right.

That’s the future of valuation management. That’s EVP.

Businesspeople love to talk about relationships. We say things like “I don’t want to just sell stuff to people, I want clients that I build relationships with.” And that’s a worthy goal – work’s a lot more fun when you know your clients and like doing business with them.

But what about the clients you don’t get to build that kind of relationship with?

For AMCs, that’s the borrower.

Sadly, most AMCs focus entirely on the lender because that’s who they interact with the most. 

But that means the other client – the borrower – is ignored.

And that’s what Every Valuation is Personal is about – remembering and serving the borrower. That’s why our internal culture building focuses on “One.” We want all of our people to remember that the person behind every order – the borrower – is the One we’ve got to think about, not the order number.

There’s a saying “brownie points have no shelf life” that’s usually meant as a warning to those who think that doing things around the house might get you out of trouble for doing something stupid later (author’s note: it does not!).

To put that saying in the context of our business, we may get some brownie points from lenders, but borrowers can’t give us credit for other orders: they don’t have any!

For the one borrower on that loan, it’s the only order. It’s a One of One. This is their home. Or it could be their business. It’s where they want to start a family, or retire, or vacation. In other words, this order is personal.

And whose job is it to make sure they get in their home? Ours.

Because the lender doesn’t want to hear that someone on their end forgot to upload the old appraisal with the correct square footage or that the borrower waited until two days before closing to schedule the inspection. 

Why? Because the borrower doesn’t care – they just want their home.

And there are no “business days” when you’re waiting for that.

Every order is an opportunity to help make one person or one family really happy. And we may never even interact with them. We believe that if we focus on that – the One borrower on every order – then our relationship with our lenders will take care of itself.  

The issue of appraisal bias continues to loom large. Going forward, there is every reason to expect it to be top-of-mind with regulators, the GSEs (Fannie Mae, Freddie Mac and the Federal Home Loan Banks), wholesale lenders, and individual borrowers alike.

At EVP, the question we want to help you answer is “how can we be prepared for it?”

Step 1: Define It

What is bias? How does one know if he or she is influenced by it? To help us understand the issue, here are some useful definitions from the Department of Justice (“DOJ”):

Bias is a human trait resulting from our tendency and need to classify individuals into categories as we strive to quickly process information and make sense of the world.

With explicit bias, individuals are aware of their prejudices and attitudes toward certain groups. Overt racism and racist comments are examples of explicit biases.

Implicit bias involves all of the subconscious feelings, perceptions, attitudes, and stereotypes that have developed as a result of prior influences and imprints. It is an automatic positive or negative preference for a group… However, implicit bias does not require animus; it only requires knowledge of a stereotype to produce discriminatory actions…With implicit bias, the individual may be unaware that biases, rather than the facts of a situation, are driving his or her decision-making.

– DOJ: Understanding Bias: A Resource Guide

Importantly, bias isn’t just about race. Fannie prohibits the:

development of a valuation conclusion based either partially or completely (on any of the following) of either the prospective owners or occupants of the subject property or the present owners or occupants of the properties in the vicinity of the subject property:

• Sex
• Race
• Color
• Religion

• Disability
• National Origin
• Familial Status
• Any Protected Class

Step 2: Avoid It

The way to avoid bias is to look for potential signs of it. We use the phrase “signs of it” intentionally because it’s important to not assume the worst. A good example is related to something we’re very proud of, which is our proprietary bias word check software. Every appraisal report is run through this software to check for a list of words to avoid (see similar list from SmartMLS). The results of the word check, however, are not the final, well, word.

For example, the word “white” is in the list, but there are plenty of legitimate uses of that word (e.g. if the street is White Ave). So every flagged word has to be read in context by an experienced reviewer to remove false positives.

For more context and some examples, the following is from Fannie’s list of unacceptable appraisal practices:

use of unsupported assumptions, interjections of personal opinion, or perceptions about factors in the valuation process and the use of subjective terminology, including, but not limited to:

• pride / no pride / lack of pride of ownership
• poor neighborhood
• good neighborhood
• crime-ridden area
• desirable neighborhood or location
• undesirable neighborhood or location

– FNMA Selling Guide: B4-1.1-04, Unacceptable Appraisal Practices (02/02/2022)

Step 3: Fix It

A good example from above that can easily find its way into a report is “desirable / undesirable neighborhood.”  Consider: desirable to whom – Old? Young? Black? White? And why? If there are neighborhood amenities, list them. If home prices are high or properties are selling quickly, that will be reflected in the comps and housing trends. There’s no reason to subjectively opine on a property’s or neighborhood’s “desirability.” List the objective facts only.

Step 4: Learn from It

“Describe the property, not the people.”

The above quote is from SmartDesk, and it’s a pretty amazing summation of how to review the language in a report. If there’s language you’re not sure about, whether your own (as an appraiser) or someone else’s (as a lender or AMC), ask yourself “does this describe the property or the people?” And “people” includes all the people involved – the borrower, the seller, the neighbors, and people “like them.” And people “like you.” Avoid language that describes them or centers them / speaks for them.

Although everyone has implicit biases, research shows that implicit biases can be reduced through the very process of discussing them and recognizing them for what they are. Once recognized, implicit biases can be reduced or “managed,” and individuals can control the likelihood that these biases will affect their behavior.

– DOJ: Understanding Bias: A Resource Guide

The bottom line is that all of us have things to learn through this: lenders, appraisers, AMCs. If we all work together we’ll have a better process and an even better experience for borrowers.

By KIMBERLEY HAAS for The Mortgage Note

As 94% of surveyed lenders agree that appraisal modernization efforts are valuable, two leaders who have witnessed the industry changing say new technology is making things possible that could have only been imagined in the past.

Dean Kelker, Senior Vice President and Chief Risk Officer at SingleSource Property Solutions, and Todd Rasmussen, President of Equity Valuation Partners, recently sat down for interviews with The Mortgage Note, and this is what they had to say.

“The lending process itself has changed quite a bit. It is certainly much faster than it was years ago largely because of the technology that’s been driving it,” Kelker said. “Most recently, largely due to the low interest rates, we have had a large volume of refinance activity in the industry the last few years. The appraisal process has changed, as well as many of the other elements of the lending process.”

Kelker cited digital imaging and electronic reports as helping to move the process along faster for homebuyers. Still, with home prices soaring in some parts of the country, it’s a hard job to be an appraiser, especially in certain places such as the Northeast and Southeast.

“Oftentimes, the price increases begin to happen before the data really catches up,” Kelker said. “In some of the hottest markets, a lot of the contracts basically say the buyer is going to be responsible for any shortage that appears on the appraisal.”

Rasmussen said desktop appraisals are widely accepted because during the height of the COVID-19 pandemic they provided an opportunity to limit face-to-face contact during the home appraisal process.

According to Rocketmortgage.com, a desktop appraisal is a property valuation that is completed at the appraiser’s desk, using tax records and information listed on the multiple listing service, or MLS. The appraisers never go to the property.

“To be called desktop, they can’t go to the property,” Rasmussen said.

Rasmussen said no matter how the appraisal is done, people sometimes feel as the person conducting the work is cold and quiet. There is a reason for that, he explained.

“An appraiser’s job is to figure out the value of the home,” Rasmussen said. “The appraiser is impartial. They are independent of the process.”

On June 20, it was announced that Equity Valuation Partners had launched Inhabet. It is a one-stop platform that empowers lenders to generate their own compliant estimate of value for residential and commercial real estate properties.

EVP Founder, CEO, and Principal Drew Watson said in a statement that with the unveiling of the Inhabet platform, they have made it possible for a lender’s trained staff to complete an estimate of value themselves.

“When appraisal management companies first emerged after the financial crisis, I saw an opportunity to transform appraisals for appraisers, banks, credit unions and portfolio lenders with a product that did not require an appraiser’s inspection,” Watson said.

To better understand lenders’ views on appraisal modernization, including benefits, implementation challenges, and possible applications, Fannie Mae’s Economic & Strategic Research Group surveyed senior mortgage executives in February 2022 using its quarterly Mortgage Lender Sentiment Survey.

Among others, the study revealed the following key findings:

• 94% of the surveyed lenders agreed that appraisal modernization efforts are valuable to the industry.
• Similarly, nearly all lenders agreed that current tools, such as Collateral Underwriter, are helpful in managing collateral risk (94%). They noted that the tools provide an extra layer of due diligence and boost lenders’ confidence in appraisals.
• “Shortening loan origination cycle time” was overwhelmingly cited as the most important potential benefit of appraisal modernization, followed by “enhancing appraiser capacity” and “lowering consumer/borrower costs.” The benefits associated with appraisal quality and risk management were also considered important by many lenders, including enhancing data quality, increasing confidence, reducing errors, and lowering repurchase risk.
• Lenders cited “the speed of industry-wide adoption” as the biggest implementation challenge, followed by “integration with loan origination systems” and “integration with GSE automated underwriting systems.” 
• “Inspection-based appraisal waivers” and “nontraditional appraisals (e.g., desktop appraisals or hybrid appraisals)” were cited as the areas most likely to benefit from adoption. Additionally, one-third of lenders think it would be helpful to “incorporate tools such as image recognition or GIS (geographic information systems) into the scoring logic of underwriting or quality-control tools.”