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	<title>Comments on: New appraisal rules BAD for the borrower</title>
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	<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/</link>
	<description>mortgage info for the D.C. metro area &#124; guidelines, updates, news, loan officer insight &#38; approval, rates, terms, fees..</description>
	<lastBuildDate>Thu, 31 Dec 2009 15:59:01 -0500</lastBuildDate>
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		<title>By: Good rates, good inventory, bad appraisal process &#124; Mortgage Blog</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-3/#comment-3163</link>
		<dc:creator>Good rates, good inventory, bad appraisal process &#124; Mortgage Blog</dc:creator>
		<pubDate>Thu, 03 Sep 2009 17:05:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-3163</guid>
		<description>[...] problem is the current crop of appraisers being used has included some who are inexperienced in or unfamiliar with the local market.  In addition (or, perhaps, as a result), too often they have used distress sales (foreclosures [...]</description>
		<content:encoded><![CDATA[<p>[...] problem is the current crop of appraisers being used has included some who are inexperienced in or unfamiliar with the local market.  In addition (or, perhaps, as a result), too often they have used distress sales (foreclosures [...]</p>
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		<title>By: Dave Ganapoler</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-3/#comment-3036</link>
		<dc:creator>Dave Ganapoler</dc:creator>
		<pubDate>Wed, 17 Jun 2009 00:07:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-3036</guid>
		<description>poorest conditioned homes in my neighborhood.  
  
Thirdly, none of the remodeled comps had all new electrical wiring with a 200 amp service, all new copper plumbing, a swimming pool with or without solar heat, supplemental solar electrical power, an insulation package that includes perimeter wall insulation, roof insulation with a radiant barrier, and double pane windows throughout.

In addition, renewable and recycled materials were used for all of the cabinetry, counters, and floor coverings.  No products were used that included solvents, created off gassing, or contained environmental contaminants -- creating a safe, toxic free home.  

And finally, a high efficiency  condenser boiler with comparable radiators, energy star appliances, water saving fixtures, and a drip irrigation system round out the improvements that set this real estate apart from ALL the properties that have been sold and are currently for sale.</description>
		<content:encoded><![CDATA[<p>poorest conditioned homes in my neighborhood.  </p>
<p>Thirdly, none of the remodeled comps had all new electrical wiring with a 200 amp service, all new copper plumbing, a swimming pool with or without solar heat, supplemental solar electrical power, an insulation package that includes perimeter wall insulation, roof insulation with a radiant barrier, and double pane windows throughout.</p>
<p>In addition, renewable and recycled materials were used for all of the cabinetry, counters, and floor coverings.  No products were used that included solvents, created off gassing, or contained environmental contaminants &#8212; creating a safe, toxic free home.  </p>
<p>And finally, a high efficiency  condenser boiler with comparable radiators, energy star appliances, water saving fixtures, and a drip irrigation system round out the improvements that set this real estate apart from ALL the properties that have been sold and are currently for sale.</p>
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		<title>By: c bowen</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2994</link>
		<dc:creator>c bowen</dc:creator>
		<pubDate>Fri, 05 Jun 2009 19:04:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2994</guid>
		<description>The way appraisers are doing there job anymore we might as well do away with them and just use a technology solution like zillow as does not matter how the house compares in quality to the neighborhood or city it is located.  They only take an average as a cost / sq ft and multiply away.  What a waste of money.  
Most appraisal firms are now national and have no idea of local market and will send in someone who can quickly make sure no glaring signs of large investment to be made then send report to a clerk who runs a few comps and viola a unrealistic dollar value is applied to a home.  Sometimes it is way high sometimes way low.  Tell me what value this is?</description>
		<content:encoded><![CDATA[<p>The way appraisers are doing there job anymore we might as well do away with them and just use a technology solution like zillow as does not matter how the house compares in quality to the neighborhood or city it is located.  They only take an average as a cost / sq ft and multiply away.  What a waste of money.<br />
Most appraisal firms are now national and have no idea of local market and will send in someone who can quickly make sure no glaring signs of large investment to be made then send report to a clerk who runs a few comps and viola a unrealistic dollar value is applied to a home.  Sometimes it is way high sometimes way low.  Tell me what value this is?</p>
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		<title>By: New appraisal rules STINK &#124; hurts borrowers &#124; Mortgage Blog</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2972</link>
		<dc:creator>New appraisal rules STINK &#124; hurts borrowers &#124; Mortgage Blog</dc:creator>
		<pubDate>Wed, 03 Jun 2009 19:10:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2972</guid>
		<description>[...] is shameful.  HVCC/the new appraisal rules are bad for borrowers Please share your thoughts [...]</description>
		<content:encoded><![CDATA[<p>[...] is shameful.  HVCC/the new appraisal rules are bad for borrowers Please share your thoughts [...]</p>
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		<title>By: Brent Mendelson</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2855</link>
		<dc:creator>Brent Mendelson</dc:creator>
		<pubDate>Thu, 30 Apr 2009 03:46:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2855</guid>
		<description>had an appraiser come out to check my house out recently. This was for a refinance. I have gone through the process a couple times before, so I’m not new to it. My house was built in ‘33 and has been a rental for years, so it’s not real pretty. Still, the appraiser’s report was filled with glaring untruths. As a result, my refinance is in jeopardy. The appaiser said that I had a leaky roof which is totally untrue. In fact, about 7 years ago, a brand new roof was installed (two years before I bought it). She saw evidence of leaking from years ago, and concluded that the leakage was recent, and that my roof needed repairing. She also said that I had a water damage problem in my hallway, which is also incorrect. I was stripping old wall paper off the wall there, and she wrongly concluded that water was coming in. So, what does a home owner do about crummy appraisers who don’t use their noggins?

THE ANSWER SADLY ON FRIDAY IS PAY FOR ANOTHER APPRAISAL!! Of course who knows that one will be any better. Hold on homeowner, you are about to embark on a long national nightmare. You too appraisers, hope you like working for peanuts and losing the very indepenant nature you use to have. I noticed appraisers used to all be in favor of this new law but now seem to be changing their tune. Welcome to reality. Better late than never. Banks should love this new law, it binds the clients to them unless they want to shell out more cash to switch lenders. Rates lower somewhere else? Too bad. Appraiser did a poor job, too bad, deal with it. This system can and will be junked but how much money and time will be wasted until it is. It is unworkable. 
It goes into effect in two days and banks are saying rules will be out in a few weeks!! 
UFB.</description>
		<content:encoded><![CDATA[<p>had an appraiser come out to check my house out recently. This was for a refinance. I have gone through the process a couple times before, so I’m not new to it. My house was built in ‘33 and has been a rental for years, so it’s not real pretty. Still, the appraiser’s report was filled with glaring untruths. As a result, my refinance is in jeopardy. The appaiser said that I had a leaky roof which is totally untrue. In fact, about 7 years ago, a brand new roof was installed (two years before I bought it). She saw evidence of leaking from years ago, and concluded that the leakage was recent, and that my roof needed repairing. She also said that I had a water damage problem in my hallway, which is also incorrect. I was stripping old wall paper off the wall there, and she wrongly concluded that water was coming in. So, what does a home owner do about crummy appraisers who don’t use their noggins?</p>
<p>THE ANSWER SADLY ON FRIDAY IS PAY FOR ANOTHER APPRAISAL!! Of course who knows that one will be any better. Hold on homeowner, you are about to embark on a long national nightmare. You too appraisers, hope you like working for peanuts and losing the very indepenant nature you use to have. I noticed appraisers used to all be in favor of this new law but now seem to be changing their tune. Welcome to reality. Better late than never. Banks should love this new law, it binds the clients to them unless they want to shell out more cash to switch lenders. Rates lower somewhere else? Too bad. Appraiser did a poor job, too bad, deal with it. This system can and will be junked but how much money and time will be wasted until it is. It is unworkable.<br />
It goes into effect in two days and banks are saying rules will be out in a few weeks!!<br />
UFB.</p>
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		<title>By: Mike Malone</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2493</link>
		<dc:creator>Mike Malone</dc:creator>
		<pubDate>Sun, 11 Jan 2009 06:12:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2493</guid>
		<description>Ken,

I just saw the question you asked about giving the borrower a heads up if the credit won&#039;t work. Yes I can do that. I can pull one bureau at no cost to the borrower. If I see a 500 score I can tell them not to do anything else. If I see an 800 score I can order the full credit report which is only 17 bucks instead of 350-500 like you charge more than likely. Wow that was easy so next question Mr. Appraiser?</description>
		<content:encoded><![CDATA[<p>Ken,</p>
<p>I just saw the question you asked about giving the borrower a heads up if the credit won&#8217;t work. Yes I can do that. I can pull one bureau at no cost to the borrower. If I see a 500 score I can tell them not to do anything else. If I see an 800 score I can order the full credit report which is only 17 bucks instead of 350-500 like you charge more than likely. Wow that was easy so next question Mr. Appraiser?</p>
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		<title>By: Mike Malone</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2451</link>
		<dc:creator>Mike Malone</dc:creator>
		<pubDate>Sat, 03 Jan 2009 00:10:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2451</guid>
		<description>No Long Island actually I don&#039;t do that. You don&#039;t know me so stop with the general comments. Did it happen yes it sure did. There should be some middle ground to reach an agreement. You didn&#039;t actuallly read anything I said, just spat out the same old tired crap about how it was all my fault as a loan officer. You are so weak and pathetic. People normally realtors have asked me to do things that are against the law. Guess what, I said NO. I am sure it cost me some business but who care?
Have the same toughnes and refuse the illegal requests. I didn&#039;t go under by being honest and neither will you.</description>
		<content:encoded><![CDATA[<p>No Long Island actually I don&#8217;t do that. You don&#8217;t know me so stop with the general comments. Did it happen yes it sure did. There should be some middle ground to reach an agreement. You didn&#8217;t actuallly read anything I said, just spat out the same old tired crap about how it was all my fault as a loan officer. You are so weak and pathetic. People normally realtors have asked me to do things that are against the law. Guess what, I said NO. I am sure it cost me some business but who care?<br />
Have the same toughnes and refuse the illegal requests. I didn&#8217;t go under by being honest and neither will you.</p>
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		<title>By: Long Island Appraiser</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2434</link>
		<dc:creator>Long Island Appraiser</dc:creator>
		<pubDate>Wed, 31 Dec 2008 20:04:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2434</guid>
		<description>Mike Malone,
          you know your gonna ask an appraiser for a ball park comp check, and then if what he tells you is not the value you were looking for GUESS WHAT your not going to talk to your borrower, your gonna go shopping around for your value. MB&#039;s killed the market by forcing apprasiers to stretch values to make your loans work. If we didnt, you went to someone who would and we would be out of business. value is what it is, it can&#039;t &quot;BR COWERDLY&quot;your comment right there is the reason why this law is going into effect. So what is a heroic value? the highest streched value you can find where apprisers skip 30 comps to go cherry picking to get your value? YOU ARE WHAT IS WRONG WITH THIS BUSINESS! I do agree that comp checks would help home owners from wasting money at times, buyt the reality is you cant have comp checks without mortgage brokers being greedy and shopping around for values. Maybe if you were assigned an appriser and you had to use them no matter what. Then they could give you comp check and be honest about it and confident that they wont loose you as a client if they dont make your &quot;target value&quot;</description>
		<content:encoded><![CDATA[<p>Mike Malone,<br />
          you know your gonna ask an appraiser for a ball park comp check, and then if what he tells you is not the value you were looking for GUESS WHAT your not going to talk to your borrower, your gonna go shopping around for your value. MB&#8217;s killed the market by forcing apprasiers to stretch values to make your loans work. If we didnt, you went to someone who would and we would be out of business. value is what it is, it can&#8217;t &#8220;BR COWERDLY&#8221;your comment right there is the reason why this law is going into effect. So what is a heroic value? the highest streched value you can find where apprisers skip 30 comps to go cherry picking to get your value? YOU ARE WHAT IS WRONG WITH THIS BUSINESS! I do agree that comp checks would help home owners from wasting money at times, buyt the reality is you cant have comp checks without mortgage brokers being greedy and shopping around for values. Maybe if you were assigned an appriser and you had to use them no matter what. Then they could give you comp check and be honest about it and confident that they wont loose you as a client if they dont make your &#8220;target value&#8221;</p>
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		<title>By: Mike Malone</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2348</link>
		<dc:creator>Mike Malone</dc:creator>
		<pubDate>Fri, 19 Dec 2008 05:37:08 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2348</guid>
		<description>The whining from appraisers just confirms that they want a paycheck and nothing else. There is nothing wrong with asking for a comp check to protect the borrower. What should happen and what I do is call and appraiser and ask what the value is. Don&#039;t give them a number to hit, just ask what it&#039;s worth. They come back and give you a ballpark and then you can go to the borrower and give them the choice if it&#039;s close. I am sick of hearing appraisers complain about bad mortgage brokers. Have some stone and do business somewhere else if they bother you with illegal requests or better yet, turn them in. Watch the new system that is coming into place next year will be a disaster for the borrowers. Do your jobs appraisers and stop crying. By the way, this new system will end up cutting into your business also, you are just too stupid and blinded by greed to see it. Doesn&#039;t matter because it won&#039;t work and will be quickly shoved aside and I say good riddance.</description>
		<content:encoded><![CDATA[<p>The whining from appraisers just confirms that they want a paycheck and nothing else. There is nothing wrong with asking for a comp check to protect the borrower. What should happen and what I do is call and appraiser and ask what the value is. Don&#8217;t give them a number to hit, just ask what it&#8217;s worth. They come back and give you a ballpark and then you can go to the borrower and give them the choice if it&#8217;s close. I am sick of hearing appraisers complain about bad mortgage brokers. Have some stone and do business somewhere else if they bother you with illegal requests or better yet, turn them in. Watch the new system that is coming into place next year will be a disaster for the borrowers. Do your jobs appraisers and stop crying. By the way, this new system will end up cutting into your business also, you are just too stupid and blinded by greed to see it. Doesn&#8217;t matter because it won&#8217;t work and will be quickly shoved aside and I say good riddance.</p>
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		<title>By: Anthony 15 yrs mtg Broker</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2252</link>
		<dc:creator>Anthony 15 yrs mtg Broker</dc:creator>
		<pubDate>Fri, 05 Dec 2008 19:52:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2252</guid>
		<description>Ken Jonson - that was kind of a good comment but a borrower is not losing much to a credit report ( what ? 12.00) vs 300.00 out the window?</description>
		<content:encoded><![CDATA[<p>Ken Jonson &#8211; that was kind of a good comment but a borrower is not losing much to a credit report ( what ? 12.00) vs 300.00 out the window?</p>
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		<title>By: Anthony 15 yrs mtg Broker</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2251</link>
		<dc:creator>Anthony 15 yrs mtg Broker</dc:creator>
		<pubDate>Fri, 05 Dec 2008 19:51:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2251</guid>
		<description>And here I am again - Brokers - Tell your borrowers what risk it will be to go Fannie Freddie as far as this appraisal law and then convince them to go with FHA - Just the MI requirement alone is a way for the borrower to sway to FHA</description>
		<content:encoded><![CDATA[<p>And here I am again &#8211; Brokers &#8211; Tell your borrowers what risk it will be to go Fannie Freddie as far as this appraisal law and then convince them to go with FHA &#8211; Just the MI requirement alone is a way for the borrower to sway to FHA</p>
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		<title>By: Anthony 15 yrs mtg Broker</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2250</link>
		<dc:creator>Anthony 15 yrs mtg Broker</dc:creator>
		<pubDate>Fri, 05 Dec 2008 19:32:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2250</guid>
		<description>Here I am again - This law might just pertain to Fannie and Freddie loans - FHA should not be affected - Brokers - stick with FHA Only - We all Know how Fannie and Freddie guidelines have progressively went south.  We as brokers know that the money given to banks ( you know the banks that have ripped off consumers for 20 years with thier late fees,  annual fees, fees to increase credit lines etc ) that it won&#039;t help the market at all UNLESS GUIDELINES CHANGE AND THE FEDS ARE NOT SAYING ANYTING ABOUT GUIDELINES CHANGING at all - These banks will simply remodel thier branches and open news ones and tell the Feds that this is how they can &quot;service the consumer&quot; and the Feds will accept it.  - if Most of you notice how the feds say how the homeowners and banks are suffereing and they never ever say anything about the people in this industry - go figure. 

 - In turn stick with FHA Only and if you have to go conventional stick with purchases only especially if they are listed with realtor - but under this new law - conventional refi&#039;s will be a rip off for the borrower - don&#039;t lead your borrower down that road - FHA MI is cheper anyway.</description>
		<content:encoded><![CDATA[<p>Here I am again &#8211; This law might just pertain to Fannie and Freddie loans &#8211; FHA should not be affected &#8211; Brokers &#8211; stick with FHA Only &#8211; We all Know how Fannie and Freddie guidelines have progressively went south.  We as brokers know that the money given to banks ( you know the banks that have ripped off consumers for 20 years with thier late fees,  annual fees, fees to increase credit lines etc ) that it won&#8217;t help the market at all UNLESS GUIDELINES CHANGE AND THE FEDS ARE NOT SAYING ANYTING ABOUT GUIDELINES CHANGING at all &#8211; These banks will simply remodel thier branches and open news ones and tell the Feds that this is how they can &#8220;service the consumer&#8221; and the Feds will accept it.  &#8211; if Most of you notice how the feds say how the homeowners and banks are suffereing and they never ever say anything about the people in this industry &#8211; go figure. </p>
<p> &#8211; In turn stick with FHA Only and if you have to go conventional stick with purchases only especially if they are listed with realtor &#8211; but under this new law &#8211; conventional refi&#8217;s will be a rip off for the borrower &#8211; don&#8217;t lead your borrower down that road &#8211; FHA MI is cheper anyway.</p>
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		<title>By: Anthony 15 yrs mtg Broker</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-2249</link>
		<dc:creator>Anthony 15 yrs mtg Broker</dc:creator>
		<pubDate>Fri, 05 Dec 2008 19:13:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-2249</guid>
		<description>I have been a mtg broker for 15 years and This law will simply make no business for anybody because comps are essential in this market today since the borrower does not know what their current value is due the declining values in the past few years. - some borrowers are clueless to value some think that since they put in a 15k kitchen that it adds 15k to value - with this law coming forth - the borrowers will get ripped off with a low value and the appraisers will get paid as usual. - It&#039;s Ok Brokers Stick together and do not do Refiannces - the Market will get even worse - just do Purchases - most purchase values should be solid especially if the property is listed with a Realtor. - the law will change if we take our stance and do not give any of these appraisers money- they will make minimum money doing appraisals ( for a few months) and then they will be cutt off - trust me on that. The lenders and Appraisers will catch hell from the Brokers and the Lenders have at least 4-5 choices - if one appraisal Company fails you DO NOT EVER GO BACK AND CHOOSE THEM AGAIN - AND LET THEM KNOW THAT THIER VALUE IS COWARDLY AND YOU WILL NEVER USE THEM AGAIN.  once a number of borrowers get ripped off by paying for appraisals and losing thier money they will stop and the refinances will cease which will show in about 90 days after this happens - Once brokers do a little work only to have it stopped by a conservative lazy appraiser they will not do refinances again - and the housing market will cease again due to refinances. - Brokers stick together we can make the mareket come back on our terms - the Country needs us to make the market come back together - if we stand firm on this the market will tank even further and they will have to change the rules.</description>
		<content:encoded><![CDATA[<p>I have been a mtg broker for 15 years and This law will simply make no business for anybody because comps are essential in this market today since the borrower does not know what their current value is due the declining values in the past few years. &#8211; some borrowers are clueless to value some think that since they put in a 15k kitchen that it adds 15k to value &#8211; with this law coming forth &#8211; the borrowers will get ripped off with a low value and the appraisers will get paid as usual. &#8211; It&#8217;s Ok Brokers Stick together and do not do Refiannces &#8211; the Market will get even worse &#8211; just do Purchases &#8211; most purchase values should be solid especially if the property is listed with a Realtor. &#8211; the law will change if we take our stance and do not give any of these appraisers money- they will make minimum money doing appraisals ( for a few months) and then they will be cutt off &#8211; trust me on that. The lenders and Appraisers will catch hell from the Brokers and the Lenders have at least 4-5 choices &#8211; if one appraisal Company fails you DO NOT EVER GO BACK AND CHOOSE THEM AGAIN &#8211; AND LET THEM KNOW THAT THIER VALUE IS COWARDLY AND YOU WILL NEVER USE THEM AGAIN.  once a number of borrowers get ripped off by paying for appraisals and losing thier money they will stop and the refinances will cease which will show in about 90 days after this happens &#8211; Once brokers do a little work only to have it stopped by a conservative lazy appraiser they will not do refinances again &#8211; and the housing market will cease again due to refinances. &#8211; Brokers stick together we can make the mareket come back on our terms &#8211; the Country needs us to make the market come back together &#8211; if we stand firm on this the market will tank even further and they will have to change the rules.</p>
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		<title>By: ken jonson</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-1980</link>
		<dc:creator>ken jonson</dc:creator>
		<pubDate>Sat, 20 Sep 2008 08:39:42 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-1980</guid>
		<description>Brent;  A question for you that will solve this &quot;debate&quot;.  Does the credit bureau give you a heads up on the homeowners credit rating before you order the credit report?  If you answer yes then appraiser perhaps should give you a heads up.  If you answer no then you have your answer on getting a heads up on value.</description>
		<content:encoded><![CDATA[<p>Brent;  A question for you that will solve this &#8220;debate&#8221;.  Does the credit bureau give you a heads up on the homeowners credit rating before you order the credit report?  If you answer yes then appraiser perhaps should give you a heads up.  If you answer no then you have your answer on getting a heads up on value.</p>
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		<title>By: George Hatch (USPAP Instructor)</title>
		<link>http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/comment-page-2/#comment-1971</link>
		<dc:creator>George Hatch (USPAP Instructor)</dc:creator>
		<pubDate>Fri, 19 Sep 2008 14:30:33 +0000</pubDate>
		<guid isPermaLink="false">http://www.choicefinance.net/blog/2008/03/31/new-appraisal-rules-bad-for-the-borrower/#comment-1971</guid>
		<description>First things first.  Every state had adopted the Uniform Standards of Professional Appraisal Practice as representing the minimum standard of conduct for licensed appraisers.  If an appraiser violates USPAP they are in violation of state regulations that govern their license.    When a loan originators asks an appraiser to perform a substandard and undocumented appraisal they are asking the appraiser to violate the regulations that govern their license.  In choosing to deal with appraisers who thus violate their own ethical standards these loan originators are deliberately choosing to deal with unethical appraisers.    

This is an incontrovertible fact that these loan originators cannot deny.  They&#039;ve all been told often enough by those appraisers who have refused to cross that line.  They know appraisers aren&#039;t supposed to accept assignments that are contingent on returning a minimum value but they routinely turn a blind eye to this corruption.  In fact, when they do this they become a willing co-conspirator in the fraud that occurs when their &quot;team player&quot; appraisers fraudulently certify on their appraisal reports that they *didn&#039;t* accept either the engagement nor the compensation for that assignment based on the promise to return a minimum value.   

Secondly, loan originators really do need to recognize that the purpose of an appraisal is not to enable their loan.  The intended use as stated on every mortgage lending appraisal assignment is to assist the lender (not the loan originator) in underwriting and making a loan decision.  Loan originators don&#039;t make underwriting decisions, they don&#039;t grant credit, and it&#039;s not their money that goes out the door.  All a loan originator does is show loan products to borrowers and sell loans to lenders. 

No appraisal report states that its intended use is to help the borrower obtain a loan and indeed borrowers are not named as intended users of appraisals.  If a report prepared by one of these &quot;team player&quot; appraisers ever did truthfully disclose that its intended use was to assist the borrower in obtaining a loan or the loan originator in booking their commission, the lender would be required by federal banking laws to reject that appraisal.  That&#039;s why these team players have to lie about the nature of these assignments and the limitations of their relationship with the loan originators.    

Because appraisals are not intended to be used as part of the marketing package the loan originators send to the lenders in hopes of &quot;selling&quot; the deal to them, there is an inherent conflict of interest when a loan originator engages the appraiser.  The loan originator isn&#039;t the one who makes the relevant decision - the lender is.    It only makes sense that the lender should be held 100% accountable for the engagement of the appraiser and their use of the appraisal.  It makes no sense to allow the lender to avoid these responsibilities and hide behind the thin veneer of plausible deniability that using outside loan orignators would seem to provide.  

It is a huge mistake for loan originators to think - or for their appraisers to allow them to proceed under the misconception - that an appraisal is worthless if it doesn&#039;t help the borrower to obtain their loan or the loan originator to book their commission.  If an appraisal prevents a lender from overencumbering a property, prevents a borrower from entering into a mortgage wherein they are already under water, then the expense of that appraisal is well justified.  

We now face multi-trillion dollar losses in the general economy that are directly related to the subversion of due diligence efforts - including appraisals and underwriting - in the real estate mortgage lending business.   Had more loan originators paid more attention to the reasons why they are required to obtain appraisals and refrained from viewing them solely as a commodity or an element of their marketing their loans to lenders we could have avoided a sizable percentage of these bad loans - because after all, these bad loans never should have been made in the first place.

The Federal Financial Institutions Reform, Recovery and Enforcement Act of 1989 recognized that the the regulated institutions had to be held accountable for the engagement and their use of appraisals.  As a result of these trillion dollar losses, it should come as no surprise to any loan originator that these regulations will be expanded upon and more heavily enforced as a result of the abuses in which many of them participated.  

Oh yeah, and a pox on your &quot;team player&quot; appraisers, too.  Had they done what they were supposed to do and refused your improper requests we wouldn&#039;t have some of the problems with loan originator ignorance that currently exist.</description>
		<content:encoded><![CDATA[<p>First things first.  Every state had adopted the Uniform Standards of Professional Appraisal Practice as representing the minimum standard of conduct for licensed appraisers.  If an appraiser violates USPAP they are in violation of state regulations that govern their license.    When a loan originators asks an appraiser to perform a substandard and undocumented appraisal they are asking the appraiser to violate the regulations that govern their license.  In choosing to deal with appraisers who thus violate their own ethical standards these loan originators are deliberately choosing to deal with unethical appraisers.    </p>
<p>This is an incontrovertible fact that these loan originators cannot deny.  They&#8217;ve all been told often enough by those appraisers who have refused to cross that line.  They know appraisers aren&#8217;t supposed to accept assignments that are contingent on returning a minimum value but they routinely turn a blind eye to this corruption.  In fact, when they do this they become a willing co-conspirator in the fraud that occurs when their &#8220;team player&#8221; appraisers fraudulently certify on their appraisal reports that they *didn&#8217;t* accept either the engagement nor the compensation for that assignment based on the promise to return a minimum value.   </p>
<p>Secondly, loan originators really do need to recognize that the purpose of an appraisal is not to enable their loan.  The intended use as stated on every mortgage lending appraisal assignment is to assist the lender (not the loan originator) in underwriting and making a loan decision.  Loan originators don&#8217;t make underwriting decisions, they don&#8217;t grant credit, and it&#8217;s not their money that goes out the door.  All a loan originator does is show loan products to borrowers and sell loans to lenders. </p>
<p>No appraisal report states that its intended use is to help the borrower obtain a loan and indeed borrowers are not named as intended users of appraisals.  If a report prepared by one of these &#8220;team player&#8221; appraisers ever did truthfully disclose that its intended use was to assist the borrower in obtaining a loan or the loan originator in booking their commission, the lender would be required by federal banking laws to reject that appraisal.  That&#8217;s why these team players have to lie about the nature of these assignments and the limitations of their relationship with the loan originators.    </p>
<p>Because appraisals are not intended to be used as part of the marketing package the loan originators send to the lenders in hopes of &#8220;selling&#8221; the deal to them, there is an inherent conflict of interest when a loan originator engages the appraiser.  The loan originator isn&#8217;t the one who makes the relevant decision &#8211; the lender is.    It only makes sense that the lender should be held 100% accountable for the engagement of the appraiser and their use of the appraisal.  It makes no sense to allow the lender to avoid these responsibilities and hide behind the thin veneer of plausible deniability that using outside loan orignators would seem to provide.  </p>
<p>It is a huge mistake for loan originators to think &#8211; or for their appraisers to allow them to proceed under the misconception &#8211; that an appraisal is worthless if it doesn&#8217;t help the borrower to obtain their loan or the loan originator to book their commission.  If an appraisal prevents a lender from overencumbering a property, prevents a borrower from entering into a mortgage wherein they are already under water, then the expense of that appraisal is well justified.  </p>
<p>We now face multi-trillion dollar losses in the general economy that are directly related to the subversion of due diligence efforts &#8211; including appraisals and underwriting &#8211; in the real estate mortgage lending business.   Had more loan originators paid more attention to the reasons why they are required to obtain appraisals and refrained from viewing them solely as a commodity or an element of their marketing their loans to lenders we could have avoided a sizable percentage of these bad loans &#8211; because after all, these bad loans never should have been made in the first place.</p>
<p>The Federal Financial Institutions Reform, Recovery and Enforcement Act of 1989 recognized that the the regulated institutions had to be held accountable for the engagement and their use of appraisals.  As a result of these trillion dollar losses, it should come as no surprise to any loan originator that these regulations will be expanded upon and more heavily enforced as a result of the abuses in which many of them participated.  </p>
<p>Oh yeah, and a pox on your &#8220;team player&#8221; appraisers, too.  Had they done what they were supposed to do and refused your improper requests we wouldn&#8217;t have some of the problems with loan originator ignorance that currently exist.</p>
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