Treasury Continues to Fund "Subprime" Loans. 10.21.09 | Personal Finance For Life / Jeff Underwood TV and Coaching

NonAMCappraiser: (October 26, 2009 1:25pm)

Valuequestor; Right On about the Qualitative analysis and the value RANGE being a more realistic objective than an actual value. The client makes the decision on a single value within this range, imagine that.I have been saying this for years. The only problem I see is that the underwriter would set the value as the bottom number in the range, which is a single value and is back where we started.

Lynn : (October 22, 2009 8:48pm)

You promote common sense and I couldn't agree with you more on your comments about qualifying low income people for housing before they're ready...while at the same time, those with stellar credit and full docs are having a challenging time getting a loan. You're right also in that the we can't say it "subprime" loans and that thinking go t us into this mess, not to mention option ARMs and declining market values. Keep up the good work. I enjoy watching your videos everyday and as a Realtor, the information provided helps me keep up to date with what is going on in the lending industry. Liked the Bugs Bunny cartoon in the background too!

Valuequestor: (October 22, 2009 11:16am)

Frank..Brian.....Love you Guys. We're all just a big stupid disfunctional family. But I'm there for you when you need me.

Chris: (October 22, 2009 6:40am)

Hey. The Treasury Direct is no good. It is not the US Govt and it only searches bonds bought from 1974 onwards!! So, if someone bought a bond from 1943, they will have NO RECORD of it. You guys need to check this crap out first before putting it on your site.

SimpleSolution: (October 21, 2009 9:26pm)

Lender-Oh and I am not highly annoyed with lenders it is just that we are asked to do things sometimes by lenders that aren't legal in our profession and I am sure you guys aren't even aware of it when you ask us to do these things so as I said this is our way of getting it out without losing you guys as clients.... :)

SimpleSolution: (October 21, 2009 9:18pm)

Lender-I feel the same way about some of my clients too(good friends). I am so bummed that I am now only allowed to work with them on FHA appraisals and they have been replaced by these clown AMC's. I have lost many good clients behind HVCC...believe me I know that you guys sometimes put a lot of work into these borrowers and then they just like that skip on you. That is why I don't do retypes in loyalty to my clients because I know how hard you guys work and then just that easily don't get paid. Yes we are supposed to always get paid but that sometimes doesn't happen either. Trust me I have got burned more than a few times on COE deals.... :)

Don from Tucson: (October 21, 2009 8:31pm)

Frank/Brian Thanks for reading and responding to my post. HFA loans are designed to be a very small segment of the housing finance market. Provisions of the bond sale required them to only help LMI FTHB families. The reason the Banks did not want competition. The only reason this was even news was the investor market HFA Bonds dried up a year ago because of subprime. The State HFA asked the government to purchase the bonds so the State FHA's could stay in business. The 13 to 19 billion dollars should be viewed as money in the pool to get rid of the inventory of foreclosed properties. The sad part is back in the day only the Banks were allowed to do the HFA mortgages. When we sold these bonds we all saw the need for Brokers rather then having the Banks to do the loans. A cycle we are now revisiting where Banks are kings of the mortgage market. Your call should be for the Bank divesting themselves of the mortgage companies they purchased with tax money. Countrywide called BoA is still CW

Joecolorado: (October 21, 2009 6:55pm)

VALUE: darn it.....I am soooo stupid....I KNEW I had heard that somewhere but I couldnt put my finger on it....apologies to all....I have been reading too many repetitive blogs and now its starting to get to me....I am not thinking straight anymore...perhaps I should become a politcian.

brian tbws: (October 21, 2009 6:13pm)

Hi real appraiser. Nicely put. Thanks for the clarification. We understand what your saying and I think you understand where were coming from. If it comes down to doing away w/ comp check as an ends to a means... then so be it. Lets not lose sight that we're all on the same page with this one. Oh I think HVCC is on its way out. Just a guess. ;)

real appraiser: (October 21, 2009 6:07pm)

brian, Final word, a comp check that does not have a file to support the conclusion is illegal. so if your appraiser keeps a file that shows all the steps to reach his conclusion, its perfectly legal. IN THE REAL WORLD, this does not happen, no file, illegal, so technically, you will hear both sides of this unless the appraiser indicates how he is doing it. My point is the words comp check does exactly what it did in this site. it happens in continuing ed courses for appraisers exactly the same way. Most appraisers here just were worried that if it is tossed around by you and frank in a way that would suggest predetermined values were ok, This would actually make an arguement FOR the HVCC, our biggest fear that it could be misconstrued, and not in our favor,I mean the real estate industries favor. The words comp check is not equal to yelling "fire" where it is clear what it is meant, but to a group of appraisers, it will have the same reaction, PANIC.

brian tbws: (October 21, 2009 5:55pm)

To all the appraiser that say we're stupid about comp checks. First "thanks for your participation." Second, I've got an inbox full from appraisers that say comp checks are LEGAL. So you may want to get on the same page before you whole heatedly attack us. Second, last I checked we're on your side... I think. We've spent time money and energy trying to overturn this stupid f@#$ing HVCC all while getting attacked. I feel like Tina and your one big Ike Turner. It appears Loves got nothin to do with it.

brian tbws: (October 21, 2009 5:48pm)

Thanks Valuequestor. I'm sure your getting the learning curve is a 2 way street. Your levity and participation is truly appreciated from our end.

Frank: (October 21, 2009 5:48pm)

Don from Tucson - We cover a lot of ground in any one story, but I think our overall vibe to this one is that HFA loans are very similar to subprime. You've got people with low income and assets and you shoehorn them into a loan. The POINT of the discussion which is even the poll question, is "why is it only the low income, low asset, FTHB that gets all the love today?" Where is the love for the well qualified guy with some money? Nowhere. In fact it seems even more difficult for the strong buyer to get a loan. It's okay though... people always call us out on the little tiny thing we said rather than the whole story.

brian tbws: (October 21, 2009 5:46pm)

Hi Guys, I dont think Rev Bonds are bad, I'm just curious why the same vigor does not go into helping the qualified borrower. It seems the guy that can buy the house is constantly getting sticks forced into his spokes. Thats all. What was the initial goal of subprime loans? The same as rev bonds. Getting people who otherwise would not qualify a home loan. That was our point. We're not making any moral judgements about those giving or receiving either loan. Simply observing

homebuggy: (October 21, 2009 4:50pm)

Okay...I don't see any sense in many of the loans being approved. I just closed a file, lady just recieved a trust fund. No history could not go Conventional, but yep FHA took it. She put 30% down and had a trust of a few million, how is that helping low income! Have another file that just closed borrower had 780 credit 5 lines of credit open for 48 months was told by an underwriter credit was thin. Why because she paid her credit card balance of all the time and the credit limit were $1000 or less. The borrower was 25! Are we nuts. Here is a 25 year old that knows how to manage her credit and pay her bills. Credit is thin!!!! Oh and she has had 3 car loans all paid as agreed since she was 17!!! the perfect borrower has trouble.

Lender: (October 21, 2009 4:46pm)

Simple Solution. I think I learned from this website that appraisers are highly annoyed with lenders of any type (Broker or Direct). I chalk this up to the fact appraisers (used to get) their business from lenders directly. Since we knew that we have been a little less tolerant than normal discourse. As a lender, we get our deals from Realtors, which annoy the hell out of me. I constantly say "I wish the Realtors knew what the hell they we're doing." I also recognize I like working with my Realtors and wouldn't change a thing. They have become friends and almost family....But they still annoy me, the same way I annoy appraisers I guess. It just goes downhill apparently. I recognize appraisers have a tough job, but they also don't have to deal with the clients for 30-60 days either, and sometimes appraisers are the only one's ever paid.

Valuequestor: (October 21, 2009 4:18pm)

Hello Clulessdad: That in a form is done for Relocation Appraisals. It would be a part of my hopes for a new standard residential form based on Qualitative Analysis. The appraiser would then have more time to work with sales data, regression analysis and trends so that the "proof" would be on/in the report. It would remove lots of the subjectivity in the appraisal. We need to be supporting a reasonable value range...not a single number. Let the underwriter/lender decide what end of the range they are comfortable with.

Deedie: (October 21, 2009 4:18pm)

Mortgage Lady. Do you have spell check? You really need it.

TheFyouSay: (October 21, 2009 4:11pm)

You get 'em Puncher. Frank and Brian For The Win!!

Valuequestor: (October 21, 2009 4:05pm)

Hello...Here is some good news: Implementation of FHA’s new policy guidance for condominium project approval and condo unit financing will be delayed until December 7th 2009. The new guidance, to be issued within the next two weeks, will: 1) offer additional leniencies to address the difficult market conditions and 2) augment some portions of FHA Mortgagee Letter 2009-19, providing additional information and clarification. Until the new guidance takes effect on December 7th, 2009 lenders may continue to use the Spot Loan Approval guidance issued in Mortgagee Letter 1996-41. Further, the site condo and manufactured housing condo project changes that have already been implemented are not affected by this delay.

Clulessdad: (October 21, 2009 4:01pm)

One glaring omission is an appraisal IMHO,is the appraiser citing all sales/area/time period. Why can't a complete set of data be included and a short reason as to why the appraiser excluded that sale? Seems to me that would make the appraisal more defensible. And answer a lot of questions upfront.

Valuequestor: (October 21, 2009 3:56pm)

I agree JG. I come to this site mostly to learn about the finance end of the biz. I learn new things every day. Sometimes I'm reminded of how little we know about each other's part in this dance. We work in a complex industry with lots of problems. I don't mind answering a question or two about what appraisers do. Hey Joe: Come on Buddy! Animal House......a quote from future US Senator Bluto Plutarski....don't leave me hanging. Everyone knows it was the Democrats that "allowed" the Japanese to bomb Pearl in order to gain more control of the government and finally get us out of the Great Depression. Hey if I don't goof off and laugh every once in a while I might fly back to DC and do some real complaining. (I started to use a different word but I know they're monitoring us.)

Don from Tucson: (October 21, 2009 3:54pm)

Frank-Brian you are dead wrong about the mortgage revenue bonds sold by State Housing Finance Agencies. Have been on both sides. These bonds perform well, very low default rates. Subprime was the greed of excessive margins designed by Countrywide and WAMU that sat on top of high index set by the Federal Reserve. To get a loan from the State Housing Finance Agency the borrower has to have a pure soul, good credit and a fully doc'ed income. Never saw a stated loan until I was in the mortgage industry, State programs don't have them.

SimpleSolution: (October 21, 2009 3:45pm)

LENDER-No offense taken. I understand your point and I hope if you read my blog below it maybe gave you and other brokers/LO's that are irritated with our bitchin an idea as to where we are comming from and why we are using this discussion board to get the word out rather than telling you guys things as our clients....

The Puncher: (October 21, 2009 3:41pm)

Seriously you assholes that throw derogatory comments at Brian and Frank need to reveal yourself. These guys are doing more for your career than you are doing for yourselves and that is a fact. I hope you do reveal yourself one day becuase we will punch a hole in your slimey fudgeing faces!

TheFyouSay: (October 21, 2009 3:31pm)

Mortgage Lady- One more thing, if you have 2 appraisals from 2 different sources that don't support value its because the value is not there. The place is not worth what you need it to be, that does not mean they are bad appraisals.

CA-AAC: (October 21, 2009 3:27pm)

ktatom - Improper conduct, "dictating to the market" generally comes under the category of attempting to influence the outcome of an appraisal report (constructive fraud), pressuring and attempting to coerce (persuade) a State Licensed Appraiser. Underwriters are just one of the participants in a highly regulated Consumer Mortgage Transaction, just like the AMC, Appraiser, Title Company & Underlying Lender. For example: If "you", as a Mortgage Broker participant, "instructed & conditioned" a State Licensed Appraiser to include or exclude certain COMPS, which is different than asking the appraiser to "consider" alternative COMPS, you could expose yourself to a "citation" (administrative fine), generally ranging from $10,000-$25,000, if you were doing business in Ohio or CA. See CA SB 237 & 239. All the Appraiser needs to do is make a File Memo (evidence, expose/make transparent) the event & share the Memo with an Enforcement Agent. You might want to consider a similar solution.

Jersey Girl: (October 21, 2009 3:01pm)

Lender: I hear you. It seems every day no matter what the topic...it always goes back to appraisal issues. I do think a lot of the issues go hand in hand (lending/appraising), but several times people were bringing up issues again days later that has nothing to do with the topic that day...like the comp check issue. That one gave me a headache. :)

TheFyouSay: (October 21, 2009 2:55pm)

Mortgage Lady. 1st off quit yer bitchen, you should be glad that they let you order a second one. Many lenders would take the 1st and kill your deal. Oh yeah, guest what PEOPLE DONT NEED TO BE YELLED AT ON THE FORUM HERE. WHEN IS THE LAST TIME YOU WERE HAVING A CONVERSATION WITH SOMEONE AND JUST STARTED SCREAMING? MAYBE YOU NEED TO TTURN OVER A NEW LEAF GO BBACK A FEW MINUTES AND CALM THE HELL DOWN.

MORTGAGE LADY: (October 21, 2009 2:26pm)

well I sent a loan to a lender and they let me transfer the appraisal WELL GUEST WHAT THEY DID NOT LIKE THE APPRAISAL AND WE HAD TO ORDER ANOTHER ONE.. GUEST WHAT DID NOT LIKE THAT APPRAISAL AND TTURN MY LOAN DOWN GO FIGURE.. I TOLD THEM TO GO BBACK TO THE APPRAISER TO REWORK THE APPRASIAL AND GET NEW COMPS.. AND THEY WILL NOT DO IT..

MORTGAGE LADY: (October 21, 2009 2:26pm)

well I sent a loan to a lender and they let me transfer the appraisal WELL GUEST WHAT THEY DID NOT LIKE THE APPRAISAL AND WE HAD TO ORDER ANOTHER ONE.. GUEST WHAT DID NOT LIKE THAT APPRAISAL AND TTURN MY LOAN DOWN GO FIGURE.. I TOLD THEM TO GO BBACK TO THE APPRAISER TO REWORK THE APPRASIAL AND GET NEW COMPS.. AND THEY WILL NOT DO IT..

MORTGAGE LADY: (October 21, 2009 2:25pm)

well I sent a loan to a lender and they let me transfer the appraisal WELL GUEST WHAT THEY DID NOT LIKE THE APPRAISAL AND WE HAD TO ORDER ANOTHER ONE.. GUEST WHAT DID NOT LIKE THAT APPRAISAL AND TTURN MY LOAN DOWN GO FIGURE.. I TOLD THEM TO GO BBACK TO THE APPRAISER TO REWORK THE APPRASIAL AND GET NEW COMPS.. AND THEY WILL NOT DO IT..

joecolorado: (October 21, 2009 2:15pm)

LENDER....the blogs and appraisers here ARE atuned to lending issues. Dont separate appraisers from the lending process..We are there to be the eyes and ears of the investor physically on site. WE are there to help protect the clients investment by informing them if there is an issue. Dont think because you instruct appraisers on a file that the job stops after you get the report. WE are first in line to be held liable for the defaulting party if the investor has a problem on foreclosure. They relied on our report so they come to US looking for payment of the excess, thats one reason why I have insurance... because I HAVE to.

Lender: (October 21, 2009 2:01pm)

My point is that these 2 guys are old lenders. I would imagine they thought they could make this a lender website for ideas and such. It turned somewhere into an appraisal website. Appraisers have these other websites to go to, and lenders don't. That's my point. Lenders got overrun by appraisers on this website. I know I can scan thru items that do not pertain to me, but I wish the volume of blogs were more intune to lending issues, that's all. Nothing personal to appraisers.

joecolorado: (October 21, 2009 1:54pm)

must be another Pearl Harbor you are thinking of...artistic license only goes so far...

Valuequestor: (October 21, 2009 1:44pm)

CA-AAC; God Bless ya! I will be on the lookout for details as they surface. Next would be to get rid of the stupid 1004 Form and the rest of the FNMA crap. The entire residential real estate industry would be far better served with an appraisal report form that concentrated on Qualitative Analysis using a modified "plus, minus, equal" system. We need to move away from the "Quantitative" form. Who the hell buys a house by going around with a little dollar adjustment checklist to compare homes they are looking at? Where do the dollar adjustments come from? (Appraiser's book of dirty little secrets) Its time my brothers and sisters for some REAL change. If not now, WHEN, if not us WHO? Did we quit when the Germans bombed Pearl Harbor?...Hell no!! Who's with me! AAhhhhgg!!!

ktatom: (October 21, 2009 1:42pm)

CA.AAC - thanks so much for the "dictating the market" comment. Of course that was my orginal thought as well as argument. Do you know where I might be able to find concrete information on that so that I can forward it to the lender. I really appreciate your comments and insight. Thanks!

SimpleSolution: (October 21, 2009 1:41pm)

Lender-I as an appraiser am going to give my two cents as to why I think all discussions turn into appraisal discussions. For years we all as appraisers have done things for our clients (some worse than others) that are against guidelines in fear of losing our clients (brokers/LO's) as we all know there are other appraisers out there that will do it and because USPAP has so many gray areas some of these things can be gotten away with. This usually starts out being done as a trainee to even obtain clients and then we as we learn we correct ourselves. I am not blaming anyone except for other appraisers for not saying no but I think this discussion board is being used as a way for us appraisers to educate brokers/LO's as to what is being done that shouldn't be and this is our way of letting it be known/heard without losing a client. We have no way of knowing if we say no to doing something if we will lose a client and therefor work. So this is out outlet if you will, I guess...

TheFyouSay: (October 21, 2009 1:35pm)

Clulessdad- Sorry for the delay but its been one of those days. B of A broker site www.bankofamerica.com/wholesale

Valuequestor: (October 21, 2009 1:28pm)

Real Appraiser: Wouldn't happen to be a USPAP Instructor, hmmm??

CA-AAC: (October 21, 2009 1:28pm)

Valuequestor - Your comments concerning the failure of USPAP and other appraisal guidelines, such as Fannai Mae's, is supported by the actual failure of US Financial Sector and the ongoing defects in appraisal reports that are currently being prepared and administrated under USPAP and Secondary Market Guidelines. USPAP was originally promoted as a means of mitigating risk, with regards to collateral security issues in Consumer Loan Transactions. You should know that a New Set of Guidelines, that includes "all participates" to a regulated loan transaction are currently being constructed for consideration as an Appraisal Industry Standard. Hopefully, those responible for overseeing the US Financial Sector, will not continue to support USPAP, Fannai Mae and other such guidelines, which have in the Real US Financial Market, been proven to be a failure.

TheBigEasy : (October 21, 2009 1:10pm)

Hey Virginia Mtg Guy. Look Here: http://www.teapartypatriots.org/State/Virginia# Or, you can simply type tea party patriots into google and look around.

real appraiser: (October 21, 2009 1:10pm)

Lender; I skip over stories that dont impact me, I try to read some to learn about the other industries, I have answered more questions from lenders than appraisers. I do not get your problem, this place is helping all learn from each other and it does not affect you at all. It is not like there is a limit to questions and answers, seriously, you just want a site dedicated to what you do not know about, cause you come off knowing everything, but the only input you ever have is to bitch about how much you hate others bitch or how you know everything, Trust me the lenders here could go to the appraisal forum ask questions all day and no one would tell them to get lost. Why the anger? do you want this web page for just you, frank and brain. What is so tuff about others asking questions that bothers you so much. We were invited here, just like you? and dont take this like I am starting something up, just asking whats your point?

ILL Appraiser: (October 21, 2009 1:09pm)

Lender-it's because of you and your appraiser that the HVCC was adopted and no doubt part of the reason we have a mess. Appraisers are not to do whatever the lender tells them to do. NO changes are to be made to an appraisal unless they are typographical. Any additional requests are to be addressed through addenda.

real appraiser: (October 21, 2009 1:02pm)

MortgageBrokerGal. The point is no changes can be made by new lender or FHA, only clarification to the original client or correction of error as posted by EdC(i figured you and I would agree on something eventually). Trust me, we appraisers hate USPAP and we have no control over its development and it is NEVER going to go away. This is not a smack against any of you but the USPAP is meant to protect us (not very well) from YOU and not give a rats ass about real life situations, USPAP IS REALLY GREY and all appraisers wish it was redone with some real life rules, clearly defined. THE USPAP IS SO BAD THAT THE SECTION OF OPINIONS GETS LARGER AND LARGER EVERY YEAR. This is how they try to explain the rules to us and trust me, even the opinions are vague, but it is not going away anytime soon Compare it to the Bible, you can interpret it anyway you want. until judgement day, you wont know if you pass/fail, by then it might be liitle too late!

Valuequestor: (October 21, 2009 12:57pm)

Sorry Lender........you were saying??

Valuequestor: (October 21, 2009 12:54pm)

As an appraiser trying to survive this s*Storm you have to follow USPAP. You may piss off a client, you may loose some business. But like those in know have already stated. If you have multiple copies of a single assignment, with discrepansies floating around in cyberspace you my friend are subject to more than the loss of a client or a "fee". Please, all skippy appraisers find another line of work, leave the building and don't let the door hit you in the tush.

Lender: (October 21, 2009 12:54pm)

No matter the topic, it turns into an Appraisal discussion immediately. I'm tired of Appraisal discussions, I don't run into these issues. Infact, when an appraisal is already done, the same appraisal just charges me $200 to put it into my name and then gets me what I need. It happens that way every time. End of discussion, please, please, please. Let's get back to u/w horror stories going on.

Frank: (October 21, 2009 12:42pm)

scmortgagemaker: Our comments are that these programs are very similar to subprime. They are people that typically can't qualify for traditional loans due to income and assets, so, it's very similar to subprime. Our POINT is that there is so much focus on this demographic, but NONE on the demographic that has no problem with qualifying for a traditional loan - get it? What are your thoughts on that?

Valuequestor: (October 21, 2009 12:39pm)

Real Appraiser, ktatom, Mtgbrokergal, James et.al. This is why I stated yesterday that USPAP combined with all of the agency guidelines has done nothging but put a big fat target on the back of appraisers. USPAP, on its own supplies lawyers with a myriad technicalities with which to "catch" appraisers doing something "wrong". When you add in all the different ageny guidelines that contradict each other and USPAP everybody looses. We need clarification. We need SIMPLIFICATION. A clear set of rules to follow. If its going to be USPAP then demand that ALL federal agencies write their rules accordingly. But you will have to clean up USPAP first. It has way too many cathes and snares. It should be clear and easy to understand. Just a freaking thought.

EdC: (October 21, 2009 12:36pm)

New lender with a new request is a new scope of work and a new appraisal. Someone was mentioning the IVPI earlier. Per a Ms. Doty at Fannie, she said it will be established next month. Sure are taking their time.

MortgageBrokerGal: (October 21, 2009 12:33pm)

real appraiser: I don't believe anyone has asked to have the name of the lender changed on the file. That case number is owned by FHA, and they are only asking for additional data. As long as the lender now holding that appraisal file has evidence that the case number has been transferred to them, they can ask for anything they want. In FHA's eyes, the Conditional Commitment is the final verification of value, not the URAR.

EdC: (October 21, 2009 12:32pm)

real app is right, you can't change the report for anyone other than the original client, and then only if there's obvious errors. These amc's want you to add their avm comparables and that is also a USPAP violation. FHA can say it doesn't matter but they're not under the same regulations as us.

real appraiser: (October 21, 2009 12:23pm)

MortgageBrokerGal; I may be missing the point, but the question is being asked by the second lender, not the original client. so if the original client has a request, fine, no problem with additional data. But if the lender has changed, no changes can be made to the original report, even the change of name would violate USPAP since the PURPOSE, SCOPE and USE have changed per USPAP.

MortgageBrokerGal: (October 21, 2009 12:16pm)

Okay, all of you taking me to task on the FHA appraisal review - here's the scoop. Go to Handbook 4150.1, Chapter 9. It discusses the authority of the Direct Endorsement Underwriter to perform a desk review and to request any additional information needed, in their estimation, to complete the Conditional Commitment.

scmortgagemaker: (October 21, 2009 12:10pm)

I disagree with your comments on the low income borrower this am - just because they fit into a low income category, does NOT make them a subprime borrower. We have a great program in SC for borrowers that make $53,000 and below - not exactly poverty level - at least not here in SC. They have to have pretty good credit. They just lack a down payment and these programs are great for them to assist them in getting into a home. I don't see where the "experienced" borrower is better than these folks. You should learn a little more about these programs before you call them subprime.

joecolorado: (October 21, 2009 11:43am)

The FHA class I took I was repeatedly informed the appraisal is done for FHA not the lender, so it is FHA's appraisal to decide what can be done & whether THEY will insure the loan. The case# stays with the property for that particular appraisal,it doesnt get transferred. If the new lender wants additional information there are rules they have to abide by in the FHA manual. The name of the lender is irrelevant as its FHA's appraisal. The problem is when an appraisal is sent into cyberspace..its out there...it cannot be brought back for updates/additions or information manipulation, it can be used for any reason and its got your signature on it which makes it a legal document and you are liable for that information. Why put yourself in that position? tell them to contact FHA and get back to you with the manual's book,page and paragraph# information you need,then contact FHA and ask them if it can be done. Dont just do it... trust your instinct. The 2nd lender is not your client. FHA is.

Sean: (October 21, 2009 11:41am)

Send your 800+ guy to me...I can do it...

CA.AAC: (October 21, 2009 11:33am)

KLATOM - Your example concerning an Underwriter directing and/or conditioning a State Licensed Appraiser to "bracket the subject property" is "improper conduct", with regards to the Underwriter's Administration Duty in a Federally Related Loan Transaction. What if the only COMPS available to meet this Underwriter's demand distorts the estimate of value. This violation is called "dictating to the market". The Underwriter can ask the appraiser to consider "identified" comparables that he/she know to exist, but the Underwriter is not empowered to "direct" the content or outcome of an appraisl report in a Federally Related Loan Transaction, especially to enhance the sellability or approval of the Consumer Loan under predetermined secondary market and/or other guidelines. Hope you can resolve your problems with your Unlicensed Loan Underwriter and their sub-contracted State Licensed Field Appraiser.

Clulessdad: (October 21, 2009 11:25am)

TheFyousay-I thought they were completely out of direct wholesale? Even the Countrywide outlets are downsized. Do you have their wholesale website? Can you pass it on to us?

Jersey Girl: (October 21, 2009 11:11am)

CAHighDesertAppraiser: It is a USPAP violation to change a report to a new lender's name once it has been submitted to the original client...period. Unfortunately it becomes a new assignment, new date, etc. If the appraiser is decent and nice, he/she will not charge a full fee for the new report. Just a reinspect since comps may change and he/she will have to do more work on the report, etc.

TheFyouSay: (October 21, 2009 11:09am)

Clulessdad. I have my full pipeline of conventional loans at Bank of America. They are doing wholesale/ broker loans and doing them with real deal common sense underwriting.

Clulessdad: (October 21, 2009 11:00am)

I am laughing at all of this, but it isn't the uw's that are the problem. They are getting a ton of loan buybacks from FNMA and Freddie. FNMA and Freddie have run out of money and are insolvent. They are HAMMERING the uw's. It is relentless. An uw is no longer an uw but a validator of information. A checklist checker. Another interesting fact. One of the largest buyers of brokered loans is Bank of America. They won't do wholesale themselves, but they know that it is VERY profitable to buy them from the wholesale channel. They have our money and are calling the shots. I think I will send them my used diaper.

loaner55: (October 21, 2009 11:00am)

Yep, give back what we get!

Clulessdad: (October 21, 2009 10:53am)

This is a regular conv loan, no income restrictions. Best answer I have received so far is to get a Verification of Income from her busband and 12 months of diaper receipts. Maybe I will send a used diaper?

loaner55: (October 21, 2009 10:52am)

Clulessdad - and the problem with Underwriting these days is once they ask for something that isn't on the original DU or LP it perpetuates into ' well, now we need to verify this, and that, and those'. I'm so done with all of this.

real appraiser: (October 21, 2009 10:46am)

ktatom: If you are certain that the appraiser was incompetent or negligent report them to the TALCB, google it an you will see the file a complaint section. this is for Texas only

Sue Z Homemaker: (October 21, 2009 10:41am)

Cluelessdad; is this some sort of loan with income level restrictions? (i.e. making too much would disqual the borrower?) If not, just tell them you are not using any income for that borrower and it sholdn't matter. If it's FHA or something akin, I guess that wouldn't work. I like the idea of sending in a picture of her in the kitchen with an apron on making cookies.

ktatom: (October 21, 2009 10:40am)

cont. CA.AAC - Now the loan is denyed due to the fact that the property didn't meet value and value is unexceptable. What would you do?

real appraiser: (October 21, 2009 10:38am)

CAHighDesertAppraiser: absolutely no disrespect to MTGBROKERGAL, but does she know the USPAP that governs you or is she stating what FHA allows the appraiser to do. Issues conflict all the time, ask your CE instructor that teaches USPAP. This site would not get so heated if it were not for the fact that few here, including myself, know the rules and regs of the (many) other professions, Unless you hold mutilple lic/hats. At least get the answer from people having the USPAP in their knowledge base,again this is not a slam on MTGBRKGAL, would you not aggree that the appraiser should get info from a direct source, since you may have your info from FHA and not USPAP?

ktatom: (October 21, 2009 10:38am)

CA.AAC - I'm not talking about value I'm talking about false information. For instance: I've got an appraser that didn't bracket the property. When the UW asked him to bracket the property he added two listing. The only problem is that they aren't listings at all. These properties have actually sold and sold prior to the orginal inspection. Now the UW won't take it because she won't except listings when trying to bracket a property. This is a flat out inacurracy. BTW. . it's met value everytime.

ktatom: (October 21, 2009 10:28am)

Clulessdad, Ask the underwriter if she will except an afidavit. This has worked in the past for me.

CAHighDesertAppraiser: (October 21, 2009 10:28am)

MortgageBrokerGal, thanks for the info :)

LL: (October 21, 2009 10:28am)

I'll never forget when years ago right before the real estate bubble took off the head of the Atlanta Federal Housing Athority (FHA) was quoted in the USA Today as saying that government needed to step in to control interest rates and financing as to allow everyone to own a home....and we see where that logic got us. At that time FHA has a roughly 11.4% default rate, too. You'll always have the "give me something for nothing" loans bc they cater to minorities that constantly have to be babied and pampered. If you live in an area where there are high concentrations of minorities it will always be a great place for real estate investment bc the programs will never go away. Oh, and the person that made those comments was an African American female.....go figure.

CA.AAC: (October 21, 2009 10:27am)

In reading the ongoing discussions, it appears that the "underlying issue" most benefiting parties (RE Agents, Mortgage Brokers, etc.) have with the State Licensed Appraisers, is that their appraisal reports are not meeting their personal expectations, with regards to supporting the closing of a loan resulting in a personal financial gain or commission. Without adequate merit, filing a complaint against a State Licensed Appraiser can being viewer as an "attempt to influence, blacklist or pressure the State Licensed Appraiser", which can place your RE License under examination, should the State Licensed Appraiser File a "Memorandum" of the event with an oversight administrator.

Clulessdad: (October 21, 2009 10:16am)

Just a note to all brokers. The reason we are so scrutinized is that the % of defaults from TPO's is much higher than direct lenders. Many of our brethren who are no longer in the business did this to us. I looked the other way when I saw this crap happening before. It will take a while, but the quality of the broker submissions nowadays is fantastic, per several ae's that I know. % delinquencies are down, although there still is a lot of fraud submitted to them, even now. If you know anyone doing this today, can you tell them to stop? It is up to us to police ourselves. We won't survive if we don't.

Clulessdad: (October 21, 2009 10:10am)

James-that should be interesting if it is on her tax returns. It doesn't stop there though. They won't believe my submission of her tax returns and they will query the IRS for the exact submissions to verify what I sent. It doesn't stop there either. And when they get the tax returns, they will find something else to take away income and screw up the deal. I just had that happen, because the stupid accountant said that a W-2 employee could write off their mileage to their work. Because it was called an unreimbursed employee expense, they deducted that fom his salary and the deal was sunk. This happened the day before closing. I had to find a willing CPA that would file a 1040X to make the 1040 correct. He did and we funded the next day. UGGH

calesuar: (October 21, 2009 10:08am)

SUBPRIME was bad because of its DETAILS with the formula to fail. FHA loans are the same fixed 30 yrs, only with a much lower down payment that with payments lower than rent, that is all the insurance you need. These borrowers ARE qualified, jobs, income, and credit scores. This new scenario is nothing at all similar to the subprime loan scenario of a few years ago.

real appraiser: (October 21, 2009 10:07am)

John, FHA is the Game, Like I said, USPAP (not FHA)governs the appraiser. FHA as with anyone can ask for whatever they want. and trust me they will find appraisers that will do anything. Once you change anything in the report, including the client (NOT JUST THE NAME) the whole appraisal is now subject to a new assignment, which means, completing assignment based on the conditions of the new client (PURPOSE,SCOPE OF WORK,INTENDED USERS) which means you have to answer the new clients request. FHA wont ask for changes, the UW will. You just performed 2 appraisal assignments on one report. You violated USPAP 10 different ways, and starting next year, include full disclosure violations. You do this at your own risk. TRUST ME, even if you do it and nothin happens, like running a red light when no one is around, does not make it legal.

loaner55: (October 21, 2009 10:05am)

Clulessdad - Seems to me if she showed no income for the last 2 years on her tax returns then that should be enough - oh, wait, that's logical and we all know that the current environment with Underwriters does not include make-sense underwriting! I talked with a Direct Lender last week and we were comparing what we have to go thru on a daily basis to get a loan closed. Not even close people ! Bankers do not have to play by the same rules. I know an Underwriter that works for a Direct Lender and she confirmed this. Sucks to be us !

MortgageBrokerGal: (October 21, 2009 10:04am)

CAHIGHDESERTAPPRAISER; FHA has allowed the Case Transfer on appraisals forever! If the first lender transferred that Case Number, they are now the new owners (albeit without your knowledge), and can ask for anything the original lender could have requested, up to and including a review appraisal. What you need from them prior to doing any additional work, is a copy of the Case Transfer information. Either the original lender or the new lender can get that to you.

James the Appraiser: (October 21, 2009 10:00am)

Clulessdad - maybe that is what she listed on her taxes over that past two years, will that be proof for the stupid underwriter, ha ha

SimpleSolution: (October 21, 2009 9:59am)

Cluelessdad-OMG...that is so funny. Maybe she has some pictures of her making some cookies or something....

John, FHA is the Game: (October 21, 2009 9:57am)

CAHighDesertAppraiser - my understanding from the FHA guy was that you CAN NOT change any thing in the report other than the lenders name. So no, you can't be asked to add the 1004MC or comments as to your adjustments. Ask the new lender if they will take a letter from you with the questions and answers for their file, but kepp it outside the report itself.

SimpleSolution: (October 21, 2009 9:57am)

HVCC IS AWESOME-That is the problem with some AMC's is that they basically send out a mass e mail to all appraisers in the area and the lowest bidder gets the job. So basically you are getting what is paid for. You are not getting what you pay for however. You are not getting a $400 quality appraisal. Some appraiser accepted the job for $125 and delivered a $125 quality appraisal. Why any appraiser will do this I don't know. I personally don't accept it and only work with AMC's that pay decent and don't expect me to perfom miracles in a day. I really feel bad for any of you brokers/LO's that are stuck with these kind of AMC's. I don't have an answer for you except to report that particular appraiser to their state licensing board. Just letting you guys know that I feel bad for you....and agree that what you are going through sucks.

Clulessdad: (October 21, 2009 9:57am)

This is real funny-I just got a loan approaval with a condition that is real funny-PLEASE PROVIDE EVIDENCE THE CO-BORROWER HAS BEEN A HOMEMAKER FOR AT LEAST 2 YEARS You appraisers think the uw's are just asking you guys stupid questions? Bad thing about this if I can't prove it, the deal is dead. Hopefully she shows this at the bottom of her 1040's.

loaner55: (October 21, 2009 9:56am)

Before everyone gets all happy thinkin that FHA is the next Gravy Train, better wait to see how the new appraisal guidelines affect it. I have talked to some appraisers that feel that FHA will go the same direction that conventionals did and we all know how much fun that is !

DIE FPF PROCESSING: (October 21, 2009 9:53am)

Brian. maybe you should outsource your processing. That is a no brainer deal. Might be an issue with your processors, I know it is with me!

CAHighDesertAppraiser: (October 21, 2009 9:50am)

New Lender B doesnt want a name change or new comps they just want more clarification on comp selection, adjustments, 1004mc ,etc...My question is can we do this for new lender without violating USPAP??

James the Appraiser: (October 21, 2009 9:47am)

John and ILL - sound like you did not talk to the same guy down at the FHA office. No one is going to get pinned over this and FHA is easy to work with, so you can both move on with out any problem no matter what way you took care of the deal

John, FHA is the Game: (October 21, 2009 9:44am)

rreal appraiser - Talked to FHA on Friday about this and gave them the case number as ref. They had no issue with changing the lender name as long as no other changes were made to the report, even ones the new lenders u/w asked for.

ILL Appraiser: (October 21, 2009 9:41am)

Regarding transferring the FHA appraisal from one lender to another. I spoke with an FHA rep about this a while back and this is all done between lenders. The appraiser is not involved at all. No changes in lender name. No changes period. Lender A sends appraisal to Lender B. Done. If Lender A want to be nasty and not transfer the appraisal, Lender B can contact HUD.

John, FHA is the Game: (October 21, 2009 9:41am)

rreal appraiser - Just talked to FHA on this Friday, they have no issue this transferring the report to a new lender name if you don't change the rest of the report in any way. So all he has to di s tell them he can change the lender abut nothing else, even if they u/w asks for a change. Did it Friday afternoon after talking with FHA, gaven them the case number and they were all happy

Evil Genius: (October 21, 2009 9:40am)

Lender, thanks but I don't think these guys will charge that much above the standard rate. That program is part of what they're offering.

rreal appraiser: (October 21, 2009 9:36am)

John, FHA is the Game. If you change the lender name. This is a new assignment as the client has changed. Just because fha says you can, USPAP is clear that you cant. The change in names means a new assignment, new client. Does your order say to maintain the appraisal under the same intent and use as the original, NO, they are asking for modifications and changes, change the name, slippery slope. Thats my interpretation. I had no problem changing it back in the day, but under todays USPAP, your risk is tenfold.

SDLoabBroker: (October 21, 2009 9:32am)

Frank, Send me that 800 FICO borrower. I will get him closed for you. :-)

James the Appraiser: (October 21, 2009 9:32am)

valleygirlappraiser - I'm back love, have you calmed down, taken your happy pills, that's nice dear, take the dog for a walk and get some fresh air, then well have a glass of wine and sit by the fire

real appraiser: (October 21, 2009 9:27am)

continued... to normal since Cuomo will be out of office and on his way to trying to be president, yeah, he really is. I would be very scared. No one will be around to push HVCC unless fnne/freddie make it a standard in the loan buying process. If this happens, Fannie/Freddie have to go and be replace with something else altogether

John, FHA is the Game: (October 21, 2009 9:25am)

CAHighDesertAppraiser - FHA will let you change the lenders name, but the case number stays the same. I would not make any changes for the new lenders conditions, tell them it is way it is and if they want to use the report as is they are welcome to, but all you will do is change the lender as FHA has told you that is fine.

real appraiser: (October 21, 2009 9:24am)

ktatom; Couple of things, the state lic authority over appraisers (in Texas) is the TALCB. double check that the listings were not still pend/active o', when the appraisal was signed, lot errors can not include two side by side lots, the appraisal only considers the subject lot. These are two things of a hundred the appraiser may look for. I just do not want you to turn the appraiser in when they might be right. Most likely, these things, unless they affect the final value, will not be viewed as sufficient to investigate appraiser. In other word, make sure the appraisers actions were severe enough to warrant investigation, otherwise it wont be taken seriously. 2, the HVCC will take millions every year to establish the "institue" so you can call and complain, its vague as to when it will be up and running, The HVCC agreement ends 11/2010 and if FNMA/FREDDIE still follow the rule(not law), its up to them. I think once they start buying loans outside the HVCC rule, things should go back

JJINNJ: (October 21, 2009 9:21am)

CAHighDesertAppraiser - the problem is that the original lender must have "released" the case number - but if they input the appraisal results into the FHA System - a new appraisal can not be done for 6 months. So, the new lender and the borrower would be screwed unless you are willing to work with them (obviously if this is against USPAP - then the deal is DEAD for 6 mos). Just happened to me recently - not fair all the way around!

HVCC IS AWESOME..LOL: (October 21, 2009 9:20am)

Here is my experience from the last 3 HVCC appraisals:1)"appraiser" calls client to setup appt with dogs barking and kids screaming in the background.She completes appraisal and submits int and ext photos from the WRONG house.2)HVCC appraisal transferred from Lender A to Lender B. Loan was transfered because Lender A wouldn't allow a subordination.Lender A had no issues with appraised value.Lender B refuses the first appraisal.I pay for the new appraisal. We ask for a "rush".3 weeks later the 2nd appraisal is done.Value comes in $2k higher than 1st appraisal.What a waste: at least a 3 week delay, spent $400 extra dollars and inconvenienced the borrower,just to find out the 1st appraisal was correct. 3)recert of value requested by UW.$100 is charged by appraiser to write:"value has fallen 5%".No supporting comps. No data or other facts to support this claim. Essentially, nothing more than that comment.Now,the UW wants a new appraisal. There goes another $400!68%LTV,778 FICO,23% ratios.

Lender: (October 21, 2009 9:19am)

Evil Genius. We need stated income for self employed who put 20% down and have 12 months reserves. Stated income has it's place, but only for the self employed with a chunk down and plenty of capital in the bank. Pretty simple, they would pay up to 7.5%. That's a good return to the private investors for quality loans and collateral. It's a win/win.

Dog: (October 21, 2009 9:17am)

The economy will not recover until the subprime industry returns in full force, more and more a borrowers are joinning the ranks of subprime lenders due to un employment and many other factors. The Subprime industry had a purpose but the overall industry got greedy and created 100% financing that was the true death to the entire industry, not basic sub prime lending. The sub prime lending sources need to return with sensible lending limits based upon actual credit risks. A- = max 85% LTV, B = 75-80% LTV and so on. We managed to destroy an entire orchard because we had a few rotten apples.

Evil Genius: (October 21, 2009 9:13am)

Guys, I posted earlier some highlights for a new lender and they are still putting together guidelines. I know this discussion almost 100% of the time turns into an HVCC bitchathon. If there are any brokers or lenders out there, please weigh in on what you think the biggest needs are from lenders to brokers. Don't mention 100% financing because that's not happening with this group. They're toying with assumable fixed and auto-mods when rates fall. They're talking about paying the broker for auto-mods even if the broker doesn't bring them back the loan. That's a cool concept. I have the ear of a couple of higher ups with this company and would like ideas. It's time for changes without Government involvement. Thanks, EG E-mail: mortgagebidz@msn.com

SimpleSolution: (October 21, 2009 9:08am)

Gsays-Awwwww I so agree....the word qualify is the key. Most of these people don't qualify and that is the problem. If they don't qualify then they don't have the right and they need to continue renting until they can just like the rest of us have.

ktatom: (October 21, 2009 9:05am)

These are all good solutions but I think the all american law suit will weed out the crappy appraisers faster. If we win - their E&O insurance won't carry them anymore then they'll be black balled by every AMC anyway. Oh and Valley Girl. . . .You are correct, I don't think it will happen. Cuomo's has no jurisdiction in Texas and he'd be hard pressed to prove it. Hell NY's going BK anyway. Where would he get the money to prosecute? Must I remind you that this idiot was the sec. of HUD under Clinton 97-01. Now he grandstand in cleaning up the problem he oversaw for 4 years. I'd love for this jerk to come to Texas.

Gsays: (October 21, 2009 9:02am)

I taught 100’s of 1st time buyer classes, I would ask, “Is home ownership a right or a privilege”? The answer is both! It is a privilege you earn by qualifying, income, credit etc. etc., but once you qualify then it becomes a right, and no mater what color, race etc. etc. No one should disallow you the right to own where you can qualify! Let’s not give tax dollars to those who don’t qualify, and concentrate on those who do!

real appraiser: (October 21, 2009 9:00am)

CAHighDesertAppraiser; simple answer is Lender can ask for anything they want. You can not touch report done for other client without violating USPAP.

SimpleSolution: (October 21, 2009 8:59am)

HVCC SOLUTION-I am an appraiser and I have no problem with you doing that to appraisers that deliver crappy reports. No appraiser should be using foreclosures as market sales unless it is a resold foreclosure and if a resold foreclosure is used and the subject is in good condition then adjustments need to be made so if you are getting crappy reports back like that then you have my blessings. That is what they get!

Mortgage Broker 101: (October 21, 2009 8:59am)

If you appraisers dont start coming into value then they should just get rid of all of you, most of you dont even know what you are doing anyway. If I want to comp check my FHA properties I will and if you cant get me the value I sure as hell aint going to use you. You guys have been hitting numbers throughout your careers why are you so righteous now? You know as well as I do that when you were looing for work before the HVCC you were willing to push the heck out of value to keep us as clients, hey if it walks like a duck? I find you whole profession a joke, some of you quote USPAP and have not even read the damn book. You guys have been in violation for ever but now your ethical? right, give me a break!

CAHighDesertAppraiser: (October 21, 2009 8:56am)

Appraiser Question?? Lender A didnt do loan, new Lender B has copy of my FHA appraisal and are now asking for "conditions" to the original appraisal that wasnt even done for them. Anyone else out there have this issue?? can new lender ask for this on appraisal thats not even theirs??

brian tbws: (October 21, 2009 8:48am)

Hey Guys, We switched over to a new email server. Some of you may have gotten multiple daily's today. Sorry about that, we've temporarily shut it down for maintenance & thanks for sticking with us.

Virginia Mortgage Guy: (October 21, 2009 8:45am)

If the market doesn't improve soon I am going to be one of the under served populus who will need help... in my case keeping my home, not buying one. ...what in the hell are the idiots in DC thinking? We need to clean house and start from scratch with term limits.

HVCC 'Solution' Part THREE: (October 21, 2009 8:42am)

One more thing I have been considering doing about this messed up system is telling the clients to reject the charges on their credit card. (or I may do the same with the appraisal fees I paid FOR my clients). It really doesn't take too much time on the consumer's end, but the AMC will have to investigate it when they get the notice from the credit card issuer and spend THEIR time with a repsonse. If the AMC keep getting charges rejected from files relating to a particular appraiser, they will take action. Again, this is intentionally wasting people time, but that is the point. Going through State Boards of Appraisers will likely get you no where fast. This is civil disobedience folks. Enough time wasted by the AMCs and the appraisers will get our point across. Kinda like a reverse-boycott or a sit-in. Again, PLEASE ONLY do this for the truly BAD appraisals, but when they are bad, do it, do it in mass, do it often, and get it done.

Mortgage Dr: (October 21, 2009 8:39am)

what state are you located in James the Appraiser

Evil Genius: (October 21, 2009 8:39am)

James, if you're full doc 4.875% is around par this morning. The lender that I'm talking about is probably going to hit the market right after the first of the year. They just started building the U/W system and broker portal. But what a boon for brokers. Fresh low risk ideas. Can't wait.

James the Appraiser: (October 21, 2009 8:35am)

valleygirlappraiser - WOOOWW, slow down sweet stuff, stick to decaf, play some soft jazz, I have to run down to meet with a broker and get my starbucks, but I will be back in 30 to 45, will check in with you then, love you babe

James the Appraiser: (October 21, 2009 8:31am)

Any LO, what is the best 30 yr fixed I can get today with those numbers any way

valleygirlappraiser: (October 21, 2009 8:30am)

James the Appraiser: 3 things can happen if you 'chat it up with the lender'. 1] if/when the AMC's find out that you are violating their provisions, both you AND the lender will be kicked off their system. 2] that AMC will inform all the other AMC's, and you & that lender will kick you off any other panel. 3] your name will be sent to Cuomo's office and should he want to, he can prosecute you for violation of the code. You think it CAN'T / WON'T happen? The code was not supposed to go into effect without IVPI..but it did. FHA was not supposed to adopt HVCC...but they have.

James the Appraiser: (October 21, 2009 8:27am)

Evil Genius - that would be GREAT, I have a mortgage of $195,000 and a home value of $380,000 with a loan of 5.875% for 30 fixed. But as I am an appraiser (1099 for income) I can't get a loan refi. Note that both me and my wife have credit scores over 720, used to be like gold. Let me know if this takes off, with my LTV they should be happy to have me in their package

CA.AAC: (October 21, 2009 8:27am)

Frank & Brian - Can you guys please consider discussing New California Laws, such as SB 237 & 239 on your informative daily talk show? Many of your Blogers are talking about problems with AMC's and improper conduct, with regards to the participants of a Consumer Mortgage Transaction. Hint... It is time the participants get educated before the "citation" arrives on their desk.

hanger: (October 21, 2009 8:27am)

Hey Evil, let us know who th ecompnay is so we can submit some loans to them

EdC: (October 21, 2009 8:23am)

Send in these inept appraisers and their reports to your State Appraisal Board - in case I wasn't clear of where to file complaints.

James the Appraiser: (October 21, 2009 8:21am)

HVCC 'Solution' Part One / Two - As an appraisler, maybe the best in California, I have no issues with what you did to the appraiser in your case, I find in funny. As you said, the bad ones will be weeded out and that helps guys like me, thanks

EdC - 20 yrs appraising: (October 21, 2009 8:20am)

Sending the crappy appraiser underwriting conditions is not going to change anything. You MB's with legitimite gripes (like HVCC sol) need to complain and send these appraisals in the state board to have these appraisers investigated and sanctioned. Getting rid of the crappy amc skippy appraisers is a good start.

James the Appraiser: (October 21, 2009 8:16am)

ktatom - where are you, I wish I have you as a client, think of the crap we could cut through and the paper work and time we would save

Evil Genius: (October 21, 2009 8:15am)

I know of a group out of California that wants to revolutionize lending. First and foremost, no ties to Government. They will raise money $1B at a time for 1 portfolio at a time. Long term investment by institutional types. They'll pre-negotiate rates, so no volatility. Stated to self employed. Sub prime to non-chronic credit challenges. Jumbo to $2MM. No HVCC. Wholesale only. Possible built in modifications (if rates fall). They want to keep each portfolio fund intact for the investor. Paperless automated U/W system being built. Total common sense U/W. Other proprietary conceptual aspects to their programs also. Who wouldn't want to bypass Fannie, Freddie, FHA or VA. Only downside I see is they want 20% equity and won't allow flips. I'd like to hear what you all think!

Lender: (October 21, 2009 8:15am)

Stopblaming is crazy. Nobody says FTHB is code for minorities. The YSP is not better on FHA either. Your facts are wrong and your sensitive to racial issues that are not being tossed around as you state. Before you commit SLANDER, get your head together first.

HVCC 'Solution' Part Two: (October 21, 2009 8:15am)

Send the appraiser a TON of underwriting conditions (Doesn’t matter if they are real ones or fake ones, just send them a bunch). If you are like me, you are forced to work with particular AMC per the lenders that you work with, and the appraiser HAS to oblige and update the report. Don’t dispute the value, because you are NEVER going to win. Just send them a TON of UW conditions and make them WASTE their time as they have wasted MY time and my money (I have been covering the appraisal fees for good client’s who’s deal go south). Make them take pictures so they have to get in their car and drive. Make them provide a resume. Make them do anything you can to waste their time and sooner or later, the bad ones will be weeded out. I’d go on, but I’ll save more for my replies to the blasting I will surely get from appraisers. (if you are an appraiser and you get TBWS, you probably AREN’T one of the bad guys, but there are TOO many out there)

HVCC 'Solution' Part One: (October 21, 2009 8:14am)

I'd like to propose a new way to fight the HVCC from the inside out. At this point we've all lost transactions due to a ridiculous appraisal. Now I am not talking about the appraisal that came in 5-10 thousand short, I’m talking about the appraisals that are 10-20 PERCENT below a true market value. I just blew a rate lock and said goodbye to a $300,000 rate term refi that was not eligible for Refi-Plus. (I did a loan for these clients earlier in the year, before HVCC, and the loan was delivered to Fannie Mae AFTER it’s cut-off for eligibility.) 8 Months ago the property appraised for $420K (it’s assessed through the city for $450K) and now this HVCC ‘compliant’ appraiser comes up with $330K, with his FIRST comp being a foreclosure, the subject’s square footage was different in THREE SPOTS on the appraisal, and so on!!! So here is what I did (and please ONLY do this if the appraisals are truly ridiculous):

James the Appraiser: (October 21, 2009 8:13am)

ktatom - Yup, we just need Fannie and Freddie to come to the same understanding that you and I have reached, then HVCC would just drop out of sight. The only reason it is used today is that they require it, get them to drop it and we are back to doing business the old way, the right way, and bad appraisers will be out of work FAST

ktatom: (October 21, 2009 8:13am)

Texas Gal, I'm collecting information but I'm not going to call. You can go up to 10K in small claims court in Texas. I'm going to sue these jerks for neligence and then have my clients do the same. It would be so easy to prove.

ktatom: (October 21, 2009 8:08am)

Alright then James. Let's just call off HVCC all together. We don't need HB blah blah blah! EVERYONE: It has been determined that HVCC no longer exists. Although we still have to go through the blood sucking AMC's communciation is wide open. Please email comps, get value checks and argue value as you deem appropriate. After all there's no one to enforce this thing therefore it doesn't exist.

Texas gal: (October 21, 2009 8:05am)

Had a similar situation where the appraiser would not fix incorrect data. My client spoke with his atty who told him that he would win the case in court to collect the difference in payments between what he was paying vs what he would have paid with the refinance. He called the AMC directly and asked for the name of everyone there to be included in the law suit. they had the appraiser correct the appraisal and revalue with the correct information

Stopblamingminoritiesforgreedy: (October 21, 2009 8:04am)

I'm disappointed you guys are spreading this Bulldoodoo, Low income FTHB are not what made sub-prime, conventional loans that do NOT conform to Fannie & Freddie guidelines are subprime. low income in itself is not a harbinger of failure. In every market there is a glut of foreclosures in the below 100K price range. This is a golden opportunity to reduce this inventory by placing "Low Income FTHB" in properties that are truly affordable. Low income is neglible if the current DTI and income verification standards are applied. Those Low income folks are not the ones defaulting on those Mcmansions and Florida condos. HYPOCRITES you cried when seller financed downpayment assistance was ended, most recently you bemoaned FHA increasing the Downpayment to 5%. The "solution" to subprime lending you promoted was FHA ( The single most defaulted on loan program) why because the YSP is better. The majority of the folks struggling with their home today are not the "low income FTHB" code for minorities

Is it true: (October 21, 2009 7:58am)

Yeeehaaa Frank, what crap are you trying to sell to us today? Hey everyone! lets listen to a bunch of unreliable information/ personal opinion from the garage gurus and then support them by buying their worthless crap! Yeahhhh get some!!

txloanmama: (October 21, 2009 7:57am)

I went to the Treasury Direct link. The only bonds that you can search for online are ones purchased after 1974.

James the Appraiser: (October 21, 2009 7:56am)

ktatom - YUP, I sent a fax to the lender just last week to let them know I had completed a report for them, and that the AMC had it. I also let them know that the report was SUBJECT TO and was 29 pages and asked that if they did not get all the pages and photos to let me know and I would e-mail them the complete report. So I still talk to the lenders all the time, you should too

Britt: (October 21, 2009 7:50am)

A few years back when things were better, I spent 3 days in St Petersburg Russia. One of the glaring weaknesses of daily Russian life was their lack of Customer Service. A hold over from the Collectivist Communist days when everyone was employed but productivity and quality was horrible, as a result, Customer Service was non-existent. When you have a system that pays you no matter what (HVCC) the result is the least amount of service necessary to keep from getting fired, or in trouble. The quality that is the result of competition in the marketplace is absent because it is human nature to sink to the lowest level of service when you are going to get paid anyway. In the meantime, Russia has embarked on a Customer Service education initiative, trying to instill free market Capitalist customer service values in its' society. While here in America, we are instituting exactly the opposite (HVCC).

Frank: (October 21, 2009 7:45am)

Lender... About an hour and a half.

redline: (October 21, 2009 7:44am)

Housing...Schmousing. Low income FTHB are typically Democrat voters and supporters. Don't overlook the toooo obvious.

MTGSTOP: (October 21, 2009 7:44am)

Frank, what are HFA Bonds and who are the lenders that deal with them?

MTGSTOP: (October 21, 2009 7:42am)

The Treasurry Direct per their instructions, does not help for anything prior to 1974. So all those War Bonds wouldn't be found

ktatom: (October 21, 2009 7:33am)

James – I’m Intrigued by all that! We’ll if there’s no one to complain to, we should all just go back to doing it the way we use to. Of course we have to go through the AMC but once we find out who the appraiser is we should chat it up. I mean . . . . who’s going to complain and even if you wanted to who would you complain to?

Rondon: (October 21, 2009 7:29am)

I knew our collective memories were short, but we are now implementing aggressive FTHB programs into the mix when we haven't even recovered yet from the first round of expanding home ownership? The "messiah", Barney Frank, and ACORN might just be able to pull it off.

Starving Appraiser: (October 21, 2009 7:27am)

JEEZ-UW horror stories are chilling!!!OVERKILL by UWs sound like. MIDDLE CLASS, as I understand is $250K+ income per year, which I'm not in. I say there are now 4 income Classes, 1.poverty, 2.WORKING CLASS-that's me, 3.Middle & 4.Upper. I now aspire to be middle class, thought I was for a long time, but guess not, as defined by income.

James the Appraiser: (October 21, 2009 7:23am)

ktatom - my understanding is that CUMO took the millions to setup the complaint system, but where he put the funds is unknown, did you check his overseas accounts

Lender: (October 21, 2009 7:14am)

Jersey Girl, I have a deal right now where the buyer already owns 29 units and is a landlord. He's buying another investment property (SFR). His income is rental income, he has no mortgages on his units. He deposits $14,000 a month on the 9th of the month, every month. This is his rental income from people paying on or near the first of the month. The u/w wants me to prove these monthly deposits are this guys rental income deposits. It's his only deposit each month. Since some folks pay rent in cash we can't source it. The u/w asked me to get a letter from the bank manager stating this guys deposits are always rent he receives. The bank manager laughed at me for asking and said "No way I'm saying what that money is from, how do I know." Even though the u/w approved the file based off his tax returns using the rental income, I still needed to prove the monthly deposits were rent. I couldn't get it. Deal dead. This was an 800 score, NOO, SFR with 25%down.

Jersey Girl: (October 21, 2009 7:02am)

I caught the tail end of a TV show last night where they were discussing housing...the VP of NAR and Dodd were there, and a member of the Mortgage Banking Assoc. The VP of NAR was saying that on top of short sales and new appraisal rules slowing the housing recovery, there are so many UW issues making it difficult for buyers. He said there was a qualified couple buying a house and they used $6K for down payment...the UW wanted to know where they got the $6K and it was b/c the couple recently got married and received the money from their wedding/guests. The UW wanted a note from every guest proving they gave them the $. What the...??? You have GOT to be kidding me. Oh and Brian and Frank are stupid blogger: you're telling me you never did a comp check in all your years of appraising? Give me a break.

Nuke 'em 'til they Glow: (October 21, 2009 6:59am)

Get rid of DPA of ANY kind and teach people how to be responsible with credit and to Save! Teach people to fish don't give them a fish! Sheesh!!

ktatom: (October 21, 2009 6:58am)

That may work in Colorado but it doesn't in Texas. I've contacted the our state agency, RESPA, FHFA, HUD, Fannie, Freddie, etc and everyone says they don't know what I'm talking about.

Lender: (October 21, 2009 6:51am)

Frank...How long does the video marketing class last? I'm definitely doing it, but figuring out when right now.

joecolorado: (October 21, 2009 6:48am)

ktatom-there is a greatcomplaint system...its called the State. report the offenders to teh State with a letter and a copy of the appraisals, explaining why there is a problem and request them to look into it. If the appraiser has done his/her job properly then S/He has nothing to be concerned about. If they have screwed up, the State will handle the offenders under their programs.

Frank: (October 21, 2009 6:43am)

No man.. we've got another email glitch in this new f-ing server... even I got it 15 times so far. I've got the bells and whistles going off with the tech guys right now.

Austin: (October 21, 2009 6:35am)

Thanks Frank!, do you need my email?

ktatom: (October 21, 2009 6:33am)

Does anyone know who we contact when we have negligent appraisers submitting appraisals to the AMC that are incorrect? I have two such situations at the moment and the appraisers are unwilling to fix the errors (wrong lot size, listings that are actually sold properties). Therefore the underwriter won’t sign off on the appraisal because it is inaccurate. You know the rest of the story. Also, Why hasn’t Fannie or Freddie created the Independent Valuation Protection Institute? My understanding is that this was a “Key” provision of the HVCC.

Sniper: (October 21, 2009 6:31am)

So, hows that "hope and change" working for ya now? Can anyone remember Carter? Well, here we go again, only this time it is going to much worse and much farther reaching! That's what we get when we put a bunch of marxists/feel good liberals in charge, and allow our politicians to continuing serving even though they continually make bad decisions against the will of the people and the good of the country. TIME TO VOTE! TAKE THEM OUT ONE AT A TIME WITH YOUR VOTE! Liberty or Death.

DAG: (October 21, 2009 6:28am)

You guys are saying what I've been saying for months! It is backwards, now when I hear Chris Dodd say he wants to give everybody who buys a house $$$, I cringe. We need to stop handing out money. It is "the economy, stupid".

Anonymous: (October 21, 2009 6:16am)

It's a cheap laugh to make fun of poor people but the fact is these programs are for the middle class. Let's face it, most of US are middle class. Why not make it easier for US?

Frank: (October 21, 2009 6:16am)

Austin - THANK YOU! I'll check it out asap!

Frank: (October 21, 2009 6:15am)

Me for Pres - Well in this particular story, it's about HFA Bonds, and typically you can broker to wholesale lenders that do these loans, at least out here in Cali we can. But I totally get your point about the ACORN thing for sure.

Austin: (October 21, 2009 6:14am)

Hey is anyone else getting bombarded with TWBS daily show? I'm getting a today's show every 5 to 10 minutes and have no way of opting out. Please make it stop.

Me for Pres( of NAMB): (October 21, 2009 6:11am)

Don't you get it? Wholesale doesn't do low income loan programs. They have to go directly to sponsoring banks, AKA Acorn thru B of A, etc. Every new program or regulation is aimed at edging out wholesale. Same old complaint but we don't have any leadership to state our case. Who wants me to handle it?

SteveH-KC: (October 21, 2009 6:03am)

The problem is that politicians and talking heads don't understand ecomomics, our ecomomy or the mortgage industry. Sad face:( These idiots won't talk to people on the street like you and me.Did you notice they don't have a Master Mind group in Washington.You would think that between that group they could get a smart guy in there. They didn't read the book!

Frank: (October 21, 2009 5:53am)

SteveH-KC... yeah we get it. I have no problem doing a loan for a FTHB on a low income program, BUT, where is the love for the other guy? The tax credit is pointed at low income FTHB's, and so is this big push to add liquidity to the HFA's. Where is the stimulus for the mid to high income qualified buyer? Can't they contribute to the real estate economy as well??? That's all I'm saying.

Texas Mortgage Professional that finds his own clients the old fashion way. WORKING: (October 21, 2009 5:52am)

Every "seasoned, quality" appraiser I know hates HVCC. They built their business on relationships, appraisals that stand up to underwriting and offering a free look-up when we needed one before spending a borrowers money if the house did not meet value they thought it could. For those Lazy, Ignorant, Can't find their own business with out being tied to an AMC appraisers. I am sure you love sitting on your thumbs waiting for the AMC phone call so you get paid for a poorly done no researched appraisal. Let's take this one step further and just give you wellfare checks and food stamps too since you can not get a loan officer to send you real business.

SteveH-KC: (October 21, 2009 5:50am)

Oh yea. What’s the other part of the story on the 800+ middle credit score guy. Can't source the DP, no real job history, not a citizen? Come on! We are leaving something out here? Is he buying a Tree house in California under 900sqft and it won't appraise for the 3mil they want to sell it for? Send that loan to me, unless of course he is one of those reasons the stupid wholesale lender won’t do it. Hmm? Think Shearson Lehman Brothers are interested! Sound like Aura deal to me. Maybe some fat cat at AIG will insure the loan. Sounds like a slam dunk to me.

Frank: (October 21, 2009 5:41am)

TD Hawk... try now.. the direct link to the start search button doesn't work for some reason so I did it one step back.

SteveH-KC: (October 21, 2009 5:38am)

I'm Realtor & LO-1)Your guys are great!Pretty savvy. 2)Please don't fall into the trap like most talking heads a blurt out problems with Low Income borrowers.Whats the Paul Harvey version of the story. No money down,10%,20%,50% down,once you have lost your job at Sprint or a car dealer.You have lost your job! Let me know that bank that will loan back some of your equity after you lost your job.Da!Most low income people are w-2 and their security is tied to the economy.Clinton has it right-"It's the economy stupid." Best program we had was FHA tied to Down Payment Assistance.Didn't cost Tax payer anything and Bush & HUD killed it. Help small bus and jobs and housing will bring us back.

joecolorado: (October 21, 2009 5:32am)

sorry that was aimed squarely at Big Mike.

TD Hawk: (October 21, 2009 5:23am)

Treasury Hunt isn't currently working. Going to the link gets you a "try again later" message. maybe TBWS caused a flood?

joecolorado: (October 21, 2009 5:18am)

perhaps you should try another job in politics. you seems to have the moral and ethical standing of most pols, you would fit it pretty well there, on top of that you could REALLY screw up the appraisal profession more efficiently that way instead of just eating it away bit by bit like you are doing....I am embarrassed and appalled that there are people that consider themselves appraisers, but have an attitude like yours. How can ANYONE trust what you say or do?so sad.....you ARE the problem....Anonimity is a shield you hide behind and greedily take what honest hard working moral and ethical appraisers pay in loss of credibility, loss of trust in the marketplace, and eventually loss of wages...what an insidiuous item you appear to be, please consider another job.

Frank: (October 21, 2009 5:09am)

Joie... no these are your state bond loans issued by your State Financing Housing Agencies. In California it would be CHFA "Chafa" loans.

bike2go: (October 21, 2009 5:08am)

I find the comment titled "Brian and Frank are stupid" humorous. This very SMART appraiser invented a word that does not exist, "unexceptable," and poor grammar, as in "no really knowledge." This illustrates our challenge. Before HVCC we could make sure we had only the intellegent appraisers and now we have to fear that we would end up with this one.

Big Mike: (October 21, 2009 4:53am)

Who are these guys anyway? It' kind of like um! but really guys USPSP has made it illegal for us appraiser to give values without a some sort of written report, and all the b.s. on how we arrived at the number. It been that way for something like 20 years. It is just that it was blowen off by most appraisers. Oh ya due to your local lender presure on appraisers it was properly done. Do you see now how lender presure works. I took a USPAP class in something like 1994 and tried for a weel or two to obey USPAP and found I was the only one and I was not getting any work. So I said screw them and start doing comp checks again. It did not influance what I thought was the correct value for a property, so no big.

big Mike: (October 21, 2009 4:42am)

The reason my last post did not make sense is this program took out the word G O D every where. I was haveing fun and made myself the new banking G O D.

Big Mike: (October 21, 2009 4:39am)

Ya Big mike as the I can just see that guy waht's his name .... Reading from the tele-prompter. "Today I want you(look left) to meet the newest (look right) member of my team. (Look left). Big Mike is going to be my new New Banking God, (look right) Why a god you may ask?(look left) Because we have to many x-rusian leaders (look right) I mean Zars(look left). I can't even remember who they all are, so Big Mike is going to just about run the whole show. (look right) Oh trust me, I know he will fix the entire (look left) mess."

Kim: (October 21, 2009 4:31am)

I agree! It's nice getting a little bit of humor each morning in times like these - and learn something too!

joie: (October 21, 2009 4:29am)

Are the same companies that made non conforming loans now making the NEW FTBH loans?

Big Mike: (October 21, 2009 4:26am)

What I want to see is simple. 1st) How about a summary judgement. The fed would review all failed stated income loans, compare the borrowers stated income an their taxes for that year. When they don't match and they never will, then the official would declair that the existing federal laws concerning bank fraud were violated. 2nd) As a result of being found guilty ALL assets is any bank, or the stock market and even the 401k, would be seized. 3rd) Those found guilty of federal bank fraud would never be allowed to borrow a dime, not even a credit card because that is just going to be the next mess anyway. 4th) Pick any 6th grade class in america, and let them run the federal reserve. Every year let the next 30 kids comming into that class rotate in the new federal reserve. I bet lending would make sence again, they wouldn't even loan their lunch money to someone who could not pay it back. 6th) Make me the New Banking God, reporting to no one I'll fix it on the first day

WB: (October 21, 2009 4:22am)

Hey guys ... ignore comments like the earlier ones from that anonymous idiot appraiser trying desperately to defend his turf. If his appraisals are as good as his spelling he's in deep trouble! Keep up the great job!

Frank is super FAT!: (October 21, 2009 4:05am)

Frank maybe you should have a diet book to plug. You need it dude

Brian and Frank are stupid: (October 21, 2009 4:01am)

Brian and Frank you need to get some appraisal education! You didn't even know that comp checks are unexceptable by USPAP. It was mortgage guys like you that F ed up. I guess you like to hear your voice but have no really knowledge