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There’s too much going on in AppraisalWorld. It is essentially impossible to keep track of what’s going on. FHFA just announced, in the most neutral of tones, that appraisal waivers could now be had, under certain conditions unheard of before. Again, conditions apply, but waivers are going to be available up to a 90% loan-to-value ratio (and 97% with a property data collection requirement). One of the conditions that applies is that the borrower would have to possess a killer FICO score. But that condition is current at the end of 2024. Given current political and social forces, who knows what those will be six-, twelve-, and eighteen-months from now? If real estate appraisal is the adult supervision of the mortgage lending industry, it appears that industry has found a way to remove the adult’s influence.
And, there’s too much going on in other areas, too. Fannie Mae is still sending letters to state appraisal boards about time and GLA adjustments. Certain states that do not accept anonymous complaints just trash them as a matter of course. Other states that accept such complaints insert those letters way at the bottom of their to do list. This may help the state with its administrative work load. But it does not help the appraiser to sleep well at night as this hangs over the appraiser’s head, family, and business.
And speaking about there is too much going on. There are now grumblings that USPAP needs to replace the ambiguous word credible (credible to whom and how to measure it?) with the word reliable. This is especially true now that the ROV process assumes the borrower is an intended user of the appraisal report.
So, what to do? Consider making friends with an administrative law attorney in each state in which you have a credential. And please make sure you have proper E&O insurance coverage.