Here is the link to the FHA Roster Appraisers Homepage:
http://portal.hud.gov/hudportal/HUD?src=/groups/appraisers
All FHA appraisers should put this page under their favorites. It's a quick and easy way to keep up with numerous FHA appraisal requirements including Mortgagee Letters, Handbooks, FAQ's and now their newsletter.
Here is the link to the Winter 2011 Newsletter: http://www.hud.gov/offices/hsg/sfh/appr/newsletter01_13_2011.pdf
Soure: ICAP eMail
FAQ – FHA 1004D Appraisal Update Completion Report
Frequently Asked Questions
FHA Appraisal Assignments
Circular No.:
2011-07-E
Date:
February 17, 2010
Distribution:
Staff and fee panel appraisers
Effective:
Immediately
The following are Frequently Asked Questions (FAQ’s) regarding LandSafe FHA appraisal assignments procedures and requirements. Included are questions regarding the use of the FHA Appraisal Update 1004D and the FHA Completion Report 1004D.
FHA Appraisal Update 1004D
Q1
Does the appraisal update 120 day extension period begin 120 days after original report’s effective date or on the effective date that the FHA Appraisal Update 1004D is completed?
The Appraisal Update Report 1004D extends the validity period an additional 120 days from the effective date of the Appraisal Update report.
Reference: HUD FAQs – ML 2009-51
Mortgagee Letter 2009-51
Mortgagee Letter – 2010-13
Q2
How many times can the FHA Appraisal Update 1004D be utilized to update the appraisal?
An original appraisal report can only be updated one time via the FHA Appraisal Update 1004D.
Q3
If the appraiser who performed the original appraisal report is no longer on the FHA Appraiser Roster, can another appraiser in good standing on the FHA Appraiser Roster perform the FHA Appraisal Update 1004D?
No. Only the FHA Roster Appraiser who performed the original appraisal report being updated and who is currently in good standing on the Roster can perform the FHA Appraisal Update 1004D. If the original appraiser is not on the FHA Roster, the lender must order a new appraisal with another appraiser on the FHA Roster.
Q4
Can a second lender, not the lender who was identified as the intended user in the original appraisal report, request the original appraiser to complete the FHA Appraisal Update 1004D?
FHA allows the original appraiser to complete a 1004D Appraisal Update for an intended user who was not identified in the original appraisal report. The original appraiser must complete the 1004D Appraisal Update and must incorporate the original appraisal report by attachment. This is a new assignment under USPAP. Since the original appraiser (staff or fee) was engaged by LandSafe, the new lender would have to engage the original appraiser through LandSafe for the update or a new appraisal would have to be ordered from another appraiser.
Note: If the appraiser who performed the original appraisal report completes an update and incorporates the original report by reference only (not attached to the original report), the Appraisal Update 1004D can only be performed for the original intended user(s), as stated in USPAP Advisory Opinion 3 (AO-3).
Reference: HUD FAQs – ML 2009-51 and Mortgagee Letter – 2010-13
Q5
Can the Appraisal Update Report be ordered after the appraisal has expired?
No. The effective date of the Appraisal Update Report must be within the 120 day expiration period of the original report being updated. Therefore, the 1004D must be ordered prior to the expiration of the original report.
Q6
Are the requirements for completing an Appraisal Update 1004D the same for FHA and conventional loans?
No. The completion requirements of the form are similar for FHA and conventional. However, FHA has the following specific requirements that are not required on the conventional Appraisal Update 1004D:
· Fannie Mae Market Conditions Addendum (1004MC) must be completed with the form
· FHA case number is to be placed on the top right hand corner of the 1004D form
· No supervisory signatures are permitted; only the FHA Roster appraiser may sign the FHA Appraisal Update 1004D.
· Appraisal update is only allowed one time for FHA
Note: The appraiser must provide a summary of the analysis conducted in the assignment to determine if the value has declined. In addition, additional certification items should be included to be in compliance with USPAP Standards Rule 2-3.
USPAP FAQ#240
Q7
Is the fee for the FHA Appraisal Update 1004D the same as the conventional Appraisal Update 1004D?
No. The fee is higher on the on the FHA Appraisal Update 1004D since the 1004MC addendum is required.
FHA Completion Report 1004D
Q8
When is the FHA Completion Report 1004D utilized?
To report the completion of a repair and/or the satisfaction of requirements and conditions noted in the original appraisal report when the subject is an existing single family residence, individual condominium, or two-to-four unit property on an FHA appraisal assignment. It can also be utilized when the DE is requesting additional issues to be addressed that were not identified in the original appraisal report.
Reference: Mortgagee Letter 2009-51
Q9
When can the FHA Completion Report 1004D not be utilized?
The FHA Completion Report 1004D cannot be used when the subject property is new construction or a manufactured home; the FHA Compliance Inspection Report (HUD-92051) must be used. The CIR remains an approved form for all FHA completion orders. The LandSafe appraiser should always deliver the product requested, unless the order is for 1004D Completion Report on new construction or a manufactured home. The appraiser should contact the LandSafe Scheduler if they are uncertain about the product that was ordered.
Q10
Who can complete the FHA Completion Report 1004D?
The appraiser that completed the original report if currently in good standing on the FHA Appraisal Roster or any other appraiser currently in good standing on the FHA Appraisal Roster. The original appraiser should be utilized unless there are some extenuating circumstances that require another appraiser to complete the 1004D (e.g. out on vacation, sick, not in good standing, deceased, has issues with their appraiser license).
Are the requirements for completing the FHA Completion Report 1004D the same for FHA and conventional loans?
No. The completion requirements of the form are similar for FHA and conventional. However, FHA has the following specific requirements that are not required on the conventional completion report, which are:
· FHA case number is to be placed in the top right hand corner of the form
· No supervisory signatures are permitted; only the FHA Roster appraiser may sign the FHA Completion Report 1004D.
Q11
Is the fee for the FHA Completion Report 1004D the same as on a conventional Completion Report 1004D?
No. Due to the higher level of inspection that is required and FHA minimum property standards that must be addressed, the FHA Completion Report 1004D has a slightly higher fee.
A BLOG for and to my many Realtor friends.
More and more appraisers are starting to utilize foreclosed sales in appraisals. It is not true that foreclosed sales should never be used in a appraisal report. Appraisers, mortgage lenders, and realtors that state this have no clue what they are talking about. Realtors should make sure these sales are adequately described in the listing and sold data. Do not just put the foreclosed property in the local MLS and state it was a foreclosure. THIS IS USELSS. Decribe in detail the condition of the home, appliances that were missing, mechanical problems, any needed repairs, concessions that were made, repair money refunded, who foreclosed on the home, if the lender made repairs, and what marketing time the REO APPRAISAL was subject to. Be truthful and many times these sales can be eliminated for use in an appraisal report, or at least give the appraiser some data in which to make an adjustment to the sale on the grid.
It is a myth that the appraiser is ask to value the home at a reduced market value just because it is a foreclosure. However, the requested lower Marketing Time by the lender usually always reflects a value well below the so called going market. Most lenders that order an appraisal on a foreclosure, request what marketing time the value should reflect. This is an important part of the puzzle that tells a knowledgeable appraiser if the property should or should not be utilized as a comparable. So Realtors ask yourself these questions when placing a sold foreclosure in the MLS. Did the lender do any work to the home? Was the foreclosure appraisal done as is? What value was put on the REO ADDENDUM of the appraisal if work was completed? What marketing time was requested on the appraisal? Any and all information you can get on the foreclosure property would be helpful. I promise if this data is truthfully obtained and placed on the sold listing, the appraiser will be able to explain to a lender why the comparable was or was not utilized in a report. Todays technology allows lenders to know whats happening in almost every neighborhood. So give the foreclosure sale more time than the normal listings and we will make it out of this foreclosure nightmare. If you need help with this, contact me at (601) 268-0900, or email me at rscottpierce@comcast.net I look forward to any comments.
New Rural Property Underwriting has me thinking twice about completing any more rural property appraisals. Last week the underwriter ask me to count the head of cattle on the property, and place a comment in the report that no money is being made from farming the land. Before that report, an underwriter ask me to place a comment in the addendum certifying that the property is not on a reservation. And last but not least wanted me to find comps within a mile of our subject. Hey Mr. underwriter!...there are no houses within a mile of the subject period. Who are these people that demand all these ridiculous comments? The dummies surely are not from Mississippi or from any rural area in the U.S. My belief is that they barely have a brain. Maybe they should look up sometimes from there guidelines so they will stop running into walls.
The next big issue is having a rural property reviewed by an in-house appraiser. You know ...the guy that got his license last month and still has no clue as to the real world rural appraisal dilemmas. If the company depends on his review to grade you, it always gonna come up short compared to appraisers that only except "cookie cutter" reports. Those reports that have three very similar comps within a month old, with a minimum of adjustments.
So in light of my experience of these issues, I have decided that no more rural properties are coming from this office. I would rather do less work and have the dummies thinking they are getting good work than work my butt off and have them thinking my report is below par. Good riddance.
Fannie Mae is working with the Federal Housing Finance Agency (FHFA) to develop and adopt appraiser independence requirements that will replace the Home Valuation Code of Conduct (HVCC). Until the revised requirements are released, the existing HVCC provisions in the Fannie Mae Selling Guide continue to apply. Updated requirements are expected to be substantially similar to the current provisions.
Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, HVCC will sunset when interim final regulations are released to implement the appraisal independence-related provisions of the Act, which is expected to occur on or about October 21, 2010.
Fannie Mae is committed to supporting strong appraiser independence requirements. The revised requirements will maintain the spirit and intent of HVCC, and continue to provide important protections for mortgage investors, home buyers, and the housing market.
The revised appraiser independence requirements will be based on Fannie Mae's experience under the HVCC and will continue to support the integrity of the appraisal process. As part of the process to develop the revised requirements, Fannie Mae has received input from key industry participants.
Fannie Mae expects to announce the revised appraiser independence requirements in an upcoming Selling Guide announcement.
Download TAVMA FEE OBJECTION LETTER 8-2010
They are asking the FRB for sufficient time to define and analyze the implications of the "customary and reasonable" appraisal fee provision of the Act.
Translation...AMC's don't want to comply with this legislation and pay appraisers a fair fee.
The TAVMA letter supports a HUD FAQ clarification in defining what a customary and reasonable fee should be:
The letter claims -
"Yet, only one agency, the Veterans Administration (VA), publishes an appraisal fee schedule, (available at: http://www.benefits.va.gov/homeloans/fee_timeliness.asp ). These fees, however, are higher than many consumers will expect to pay in a retail mortgage transaction. Moreover, VA loan appraisal fees do not purport to be “customary and reasonable” for non-VA loans. Rather, they reflect “maximum allowable fees for the appraisal type” according to the VA website. Thus lenders, AMCs, and appraisers that use the VA fee schedule are very likely to distort (by artificially inflating) appraisal fees in most markets. This could become a self-perpetuating problem, as higher “customary and reasonable” fees for non-FHA work may have the effect of increasing VA appraisal fees resulting in a vicious cycle."
"Yet, only one agency, the Veterans Administration (VA), publishes an appraisal fee schedule, (available at: http://www.benefits.va.gov/homeloans/fee_timeliness.asp ). These fees, however, are higher than many consumers will expect to pay in a retail mortgage transaction.
Moreover, VA loan appraisal fees do not purport to be “customary and reasonable” for non-VA loans. Rather, they reflect “maximum allowable fees for the appraisal type” according to the VA website. Thus lenders, AMCs, and appraisers that use the VA fee schedule are very likely to distort (by artificially inflating) appraisal fees in most markets.
This could become a self-perpetuating problem, as higher “customary and reasonable” fees for non-FHA work may have the effect of increasing VA appraisal fees resulting in a vicious cycle."
The final implementing regulation must consider these complex issues before establishing a workable and accurate set of “customary and reasonable fees.” Unfortunately, a credible source of “objective third-party” fee information simply does not exist at this time.
The premature adoption of the fee provision will cause unanticipated harm [to] AMCs, lenders, and consumers, and likely will adversely affect competition among appraisers.
The Good, The Bad, And The Ugly
While county-level analysis may seem to be the most relevant to the fees you charge on a day to day basis, there’s no denying the fact that your business doesn’t operate in a vacuum. Statewide, regional, and even national statistics have a direct and measurable gravitational effect on you too. So, moving past the micro county level and looking at the macro, find yourself in the map below.
If you’re in Census Division 3, East North Central (Illinois, Indiana, Michigan, Ohio, and Wisconsin), you’re ranked at the very bottom of the nine divisions nationally, with a median fee of $300.
If you’re in the Pacific area, Census Division 9 (with California, Washington, Oregon, Alaska, and Hawaii, plus we added Guam), then you’re in the highest median fee zone, at a very healthy $400.
Clearly, there’s a fundamental difference in the two areas. Note that the 50 most expensive locations were dominated by counties in Alaska, Hawaii, and Wyoming. And of the locations with the lowest fees, appraisers in Ohio were represented disproportionately, with 18 of the bottom 50 slots being taken by counties in the state. Four nearby states — Pennsylvania, Kentucky, Illinois, and Wisconsin — also had three to four counties each in the bottom 50.
Why Is The East North Central So Bad?The fact that the entire region is so low would seem to indicate that cost of living or oversupply of appraisers is causing the problem. But that’s not borne out by the facts. Many areas with lower costs of living, notably in the South, enjoy higher fees, for example.
And when judging potential oversupply conditions, it is true that the counties in the East North Central division have an appraiser coverage count (the number of appraisers who indicate that they cover a given county) of 41, which is 15% above the national average coverage count of 35 per county. But, that doesn’t explain why, of the 50 best counties in terms of orders per appraiser, seven of them are in this region — and yet six of the seven with the highest number of orders per person are also significantly below the national median appraisal fee, and none are above. Two of the seven with the most orders per person actually rank among the 50 worst counties in the nation in terms of median fee. So, appraiser oversupply is obviously not the cause of low fees.
The AFR doesn’t have the data to say definitively, but it isn’t beyond speculation that — since it’s essentially the backyard of the “birthplace of AMCs” and the historical home of the software vendors who touted AMC connections as their raison d’être (ACI and the former Day One, now part of ACI) — it’s quite possible that appraisers in the area have simply come to accept low fees as a way of life. Fees may over time come in line with national norms now that it’s apparent that there’s a supply/demand anomaly there, if appraisers take action.
It’s also worth noting that, in Figure 2 (PDF), the relative standard deviation (RSD%) in the East North Central is the second lowest of all divisions. So the fees aren’t just low, they’re uniformly low. (High RSD% means high variation, and lower RSD% means consistency.)Standard Deviation Ranges By StateNow look at Figure 3, (PDF) with average (not median) fees per state. Showing the average is necessary because, in Figure 4, (PDF) we add and subtract one standard deviation from the average in order to determine the likely range of the most common fees.
In Figure 4, the dividing line between the red and green bars is the same as the endpoint of the blue bars in Figure 3, meaning that the dividing line in Figure 4, is the average. The red and the green are one standard deviation below and above the average. So anything between the low and high range of the red and green bars is generally encountered about two thirds of the time.
You can instantly see that some states have a high range and some a very low range. New York stands out as a very “inconsistent” state. The urban versus rural dichotomy in New York doesn’t fully explain the variation, since similar urban/rural states like California have a variation approximately half as pronounced. So, in New York you can deviate pretty widely from the mean either way and not be out of the norm, whereas expectations would be narrower in California. And don’t even think about stepping out of line in Alaska.
In the end, it’s obvious that you need to understand your county, state, and region, so you know what latitude you have to push the boundaries of your fees — and what urgency you may have to do it.
Download your free copy of the Appraisal Fee Reference here.
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Putting Our Money Where Our Mouth Is
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Foreclosures are causing prices of condos to tumble in Mississippi Gulf Coast – falling to staggering low levels. Many projects are hanging unfinished in mid air. Many of the investors have walked off from the properties that have gone underwater. But realtors are now busy again to make sharp profits while prices are at record low levels.
The types of buyers coming in today are changed with less number of investors. More people are keen on the condos as their primary units of residence and also vacations houses. The agents of Louisiana are observing that the locals are eager to settle again into second houses in Harrison County (west).
Tashia McGinn a realtor of Beau View condo in Biloxi said, “Real estate is such a valuable commodity if you can pick it up at the right price. If you have the money to buy, it’s the right time to buy. The cost of construction right now would be double the cost of a unit.”
Condos that generally used to sell of $400 per sq ft are now being sold for $220 a sq ft. At Beau View there are still 30 units remaining unsold in a complex containing 112 condos. Beau View has been spared too many foreclosures but future plans for building more condo towers have been kept on hold until the market stabilizes.
Carlene Alfonso working for Coldwell Banker Alfonso Realty Inc. noted that some of the agents were not releasing the correct figures and holding back some details from the MLS so that prices cannot be further lowered by the investors and evaluators. In other condos the prices are much lower. Alfonso observed, “There are a lot of foreclosures, but they’re being bought up quickly. Most of these are cash sales. There are investors out there who are buying foreclosures because the prices are just unbelievable.”
Another opinion is that apart from foreclosures the condo scene has totally altered since the lashing of Hurricane Katrina. Initially the tumult had pushed off the buyers. Prior to the hurricane it was not difficult to find buyers for condos because of the growing housing bubble.
The president of Gulf Coast Investment Developers Inc. Mike Boudreaux said that his group did not have to make efforts to book condos because the condos were less costly than those in Florida. Another plus point was the annual inflow of tourists thanks to the casino culture. But after the catastrophic stork of 2005 August the sales figures were blown away by the winds.
I recently spoke to Homeownership Center to get a clarification on how they want cases handled when there are addendums to sales contracts after the appraisal has been completed. Specifically when lenders ask to change the sales price to the appraised value. Which occurs when the home does not appraise at its sales price. FHA's stance is that it should be handled in underwriting and no changes made to the appraisal. It is their belief and arguable so that it would constitute a new appraisal if facts are changed and the only time they allow for the original appraisal to have any changes is for corrections of errors or omissions and cannot take into consideration any new information that was not known and available at the time of the appraisal.I asked if that could be put in writing or sent out as a memo and they said if there were any questions the underwriter can call there known HUD Rep., as it is an underwriting issue not an appraisal issue.
I have been handling this situation in an addendum. Stating the parties have changed the sales price to ? due to the appraisal. And, per the underwriter I have included this change in this addendum, but have not changed the original appraisal or the original sales price.
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