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« Consumer Financial Protection Agency Debated in Congress
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Wholesalers Lenders Start Using AMC’s to Ensure Appraiser Independence

December 10th, 2009  |  by John Yedinak Published in MetLife, News, Reverse Mortgage  |  68 Comments

Earlier this year the Federal Housing Administration announced that it would adopt the language from the Home Valuation Code of Conduct (HVCC) to ensure full alignment with the Government Sponsored Enterprise (GSE) standards. 

While FHA is not requiring the use of an Appraisal Management Company (AMC) or other third party providers, it does require that reverse mortgage lenders take responsibility to ensure appraiser independence.

With a proposed rule putting the responsibility of correspondents on FHA mortgagees (lenders), wholesalers like MetLife are requiring that brokers use AMC’s to ensure they remain compliant.

According to a notice MetLife sent to brokers:

Effective on all loans with case #s assigned on or after December 18th, 2009, the appraisal orders must be placed with an Appraisal Management Company (AMC) to ensure that the appraisal reports are prepared by an FHA Roster appraiser who has not been selected, retained or compensated in any manner by the mortgage broker or any member of the lender’s staff who is compensated on a commission basis tied to the successful completion of a loan.

The company is requiring that appraisals be ordered through ServiceLink, Equifax, or National Real Estate Information Services.  MetLife isn’t the only wholesalers who is requiring that brokers use an AMC.

Other wholesalers like Live Well Financial will also be utilizing AMC’s to ensure compliance with FHA guidelines.  In an email to RMD, Brett Ludden, Senior VP at Live Well Financial said the appraisal ordering process will be integrated directly into its proprietary origination system to make the process easy for correspondents. 

Even if wholesalers can make the new process easy, many reverse mortgage brokers are concerned that the AMC requirement will increase the costs of an appraisal for their customers. 

“The costs on AMC managed appraisals for conventional-forward mortgages has gone from $225 to a minimum of $405 up to $680,” said Jack Belles, President of Reverse Mortgage of New England.  The company does a few “forward” loans and said he sees no reason why the costs won’t go up when wholesale reverse mortgage lenders start requiring the use of AMCs.

Most wholesalers are requiring the use of AMCs starting January 1st, 2010.

Technorati Tags: Reverse Mortgage,News,HECM,FHA,HUD,Appraisal Managemnet Companies,MetLife,Live Well Financial

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← Older Comments
  • markjudge

    The_Cynic

    Hmm, well I have never seen or heard of an appraiser charging 1 price if the loan goes through and a much lower price if it does not although I have heard of appraisers who will only charge the customer a trip charge if they arrive at the property and before measuring it or taking any pictures realize that the value is just not there. Then they actually don't do the appraisal and only charge for the trip out there.

  • Appraiser_Loft_Shane

    AppraiserLoft is proud to say that we have been utilizing a powerful wholesale appraisal process for close to a year now. Our system allows the broker or originator to order and maintain status on each appraisal through an FHA compliant portal that is built custom to each lenders specific requirements and branding.

    Considering our substantial experience in the Reverse Mortgage market and FHA loans over the last 4 years, we feel that our platform and support staff are a perfect solution for FHA wholesale lenders. In fact, we are currently applying this process to most FHA and Reverse Mortgage lenders nationwide. We know your market, your pain points and how to take great care of the senior borrower. It is what we have done for years.

    Our wholesale process is very smooth and although we expect the same sort of transition issues that came with HVCC, we feel that in the end the originator, lender and of course borrower will have a compliant and user friendly experience. Of course this will take give and take. We encourage our clients to suggest modifications and adjustments.

    FHA Invoicing and Cost Plus – Paying Appraisers Well

    AppraiserLoft has taken great pride in the fact that we pay our appraisers very well. Over the last year we have been using our “Cost Plus” process with appraisers nationwide. Under this process, we can guaranty a fee to appraisers that ensures they are well paid. Our reasonable management fee is simply applied as a separate item listed on the invoice. Not only does the “Cost Plus” process show great respect for our appraisers, it also assists in meeting the FHA requirements pertaining to distinction of actual appraisal fees vs management fees. We have been doing this for over a year as a national flat rate price and it works extremely well on a national basis.

    Not all AMC's low ball the appraiser. Do your homework on this before making assumptions. True there are many AMC's who sacrifice quality for margin, but that is not the case for all of us. In the end, it is essential that the appraisal be accurate to move your deal along. Through experience, we have learned that quality appraisers don't work cheaply. You have pay for quality work. We feel that our “Cost Plus” process addresses this fact completely.

    Bottom line is that you can have both compliance and excellent quality-service. It all depends on your appraisal partner and how willing they are to adjust and modify their process and pricing to meet your specific needs. As an appraisal partner, AppraiserLoft seeks to balance the compliance requirements with service and quality. You can have it all.

    Payment and COD

    Under most of our client scenarios, the originator will be asked to pay for appraisal upfront with credit card, e-check or by allowing our team to collect from the borrower on their behalf. Our wholesale portal will allow the originator to order and collect through the same platform. Once again, this process has been in use with most of our clients for years and it works very well even in the Reverse Mortgage market. There are other ways to receive payment besides COD. We have seen it in action for years now.

    We know that these appraisal adjustments be unwanted by some and overdue by others. If HVCC is any indication, we also know that with time and experience, the process will work smoothly. AppraiserLoft here to help with the transition.

    Best wishes to all.

  • jamesanelson

    What kind of reputable Appraiser would work on that basis? His fee
    for his knowlege of the local market and appraisal expertise is what it is (or at the very least should be), period. No if or buts. One reason I DO NOT like AMCS' is experienced, very Professional Appraisers have been paid less than their normal and reasonable fee, where I was forced to use one; the Senior Client, however, was charged even more than a normal market fee .

  • -M-

    If AMCs are NOT used, the Lender would be responsible for all the tasks the AMC currently services. Lenders do not want to inherit these responsibilities because they will not be compensated. If AMCs are NOT used and Lenders are forced to integrate appraisal management into their day-to-day operations, then we would see prices rising substantially to offset the Lender's inexperience, lack of personnel and undeveloped technology/platforms to deal with these new requirements.

    There are AMCs out there like Landmark Loan Services who have already streamlined this process with borrower's pocketbooks first in mind. The changes in price (as stated in one post) will remain largely unaffected. Static prices in ANY industry is an unrealistic expectation!

    In these times of depressed values, borrowers need to understand the uncertainty that exists. It is the broker-lender's responsibility to educate their clients to know the pros & cons of making a decision to proceed. HUD is being proactive to corral potential lawlessness before it can get started. Let us not forget values were given liberally in the traditional mortgage world putting our country into this housing market disaster.

    If a reverse is a viable financial solution for a senior homeowner then an attempt at closing despite the appraisal cost is worth a try, is it not?

    Sometimes results cannot be predicted unequivocally and costs rise — these are realities in our lives. Remember this change is intended to help our industry, not hurt it. There are plenty of other weaknesses in this industry that are far more pressing than this policy change. This is a move in the right direction.

  • t_r_fcam

    There are many alternative small regional AMCs that are concerned about the appraisers fee and the costs to borrower. We do provide a valuable service to the lender client in managing the entire order process, payment and communication.

    Our experience is that most people don't really understand HVCC, for one the communication issue is a result of the LENDERS not the HVCC. HVCC was adressing the pressure on appraisers to hit a value or never receive work again.

  • jamesanelson

    Important note: My last response was directed at The Cynic, not Appraiser_loft_Shane which RMD positioning made it appear. AMCs may work well, perhaps, if indeed the Senior Borrower interest is placed first. I'm just concerned how Loan Originators arrive at a reasonable home value prior to an expensive FHA Appraisal to ascertain whether the FHA HECM Formula will work for a young Senior with high mortgage debt. Many Seniors are in desperate financial situations: I would hate to raise a Senior's hopes needlessly.

  • jamesanelson

    By the way, if anyone wonders why I'm concerned about this problem…..I had my butt chewed out royally the other night by a very spry 80 year old
    Husband whose Wife was scheduled the next day for life threatening surgery (which undoubtedly played a roll in his attitude). Seems I was the fifth L.O to give him different FHA Formula numbers. I told him as politely as I could that I had previously emphasized that all of the numbers anyone gave him were meaningless until an actual FHA Appraisal is done. My numbers had been based on a home value and mortgage debt he had given me! And, even then, the numbers could change right up to when the final documents were provided for signature at closing..

  • chuckbanfe

    If a customer or lender orders an appraisal without knowing if it will qualify for a reverse mortgage in advance (the value is not high enough to cover their mortgage) then they will get stuck with the cost of an appraisal that was unnecessary. Seniors should not be subjected to this. HUD should allow appraisers to at least give a rough estimate of value otherwise the customer will be paying for an appraisal when they do not qualify for a reverse mortgage.

  • The_Cynic

    chuckbanfe,

    At last, a voice of reason in a sea of platitudes.

  • The_Cynic

    James,

    This practice has been in place for years. As the mortgage business began drying up, lenders began getting concessions.

    Here was the problem. Originators wanted more deals and had to reach out to seniors who were less and less afluent and were illiquid. These seniors were concerned that if they got the appraisal they could not afford to pay for it if the loan did not go through. These originators began promising seniors that if they went forward, there be no fees if the loan did not go thru (pre borrowers paying for counseling).

    Some originators (and brokers) negotiated deals that they would pay for the appraisals on loans that go thru but they needed to get a different compensation structure to offset those that did not. The agreement was that all appraisals would be charged the same, about $50 more than their current agreement per appraisal but on ones that did not, the originator would only pay $50. As appraisers saw the mortgage market drying up, some went along with these agreements.

    Such arrangements made the appraiser a party to the transaction. In essence they were paid a small base and a bonus based on success. To many of us these appraisers lost their independence.

  • The_Cynic

    -M-,

    Please we are not a bunch of simpletons. For years some lenders had their own appraisal departments or units. Usually they were in “captive” affiliated corporations.

    Price is based on what the market will bear. It is not a matter of static or non-static prices. This is simple Econ 101.

    You and I were in two different housing bubbles. If all the “lawlessness” was a simple matter of overvalued appraisals, we never would have seen a housing bubble. The real problem was a drop in lending standards. Borrowers were showing inflated income and lower expenses while lenders were lowering the minimum ratio requirements on mortgage payments to income and introductory rates on ARMs became ridiculous. Stated income and stated assets were the rule of the day.

    If inflated home values were the primary problem, then the mortgage payments would have been higher and higher and no one could afford the loans.

    Do you really think it is right to string a senior along just to see if an appraiser will come up with the needed value? Some seniors do not have the money to pay for counseling. It is obvious you do not work with borrowers. They are desperate and too many times believe their homes are worth a lot more than they are.

    Please remember, these changes are intended to reduce FHA risk not “help” the industry. Many of us believe this is a move in the wrong direction. The cost of a middleman is a real cost.

  • rmguy

    This will not work for all the valid reasons listed above. In four years doing RM's I have only had 4 deals fall apart due to under-appraisal…all with AMC's…all with the same “Top 5 ” lender. I will leave the business before I will turn my financial future over to an appraiser who discount a fee by 50% just to find work.

    This is causing a downward spiral of valuations further compounding the collapse of home values. Congress knows this and if the bureaucrats can't fix it they will rewrite the rule themself.

  • ahm111677

    I am an appraiser for 15 years now. This is the worst I have ever seen this business. About 3/4 of my work is from management companies now. The pay is horrible. I am a father of 4 little children, and am being greatly impacted by all of this. HVCC should be completely reversed. There just needs to be tougher licensing requirements. I see probably 2-3 reviews a week, and usually 1-2 are terrible reports. There are a lot of bad appraisers out there, but this is not the way to get rid of them. A friend of mine who is a loan officer asked me to look into this property for him. Through their management company, the appraiser valued the house at 340k. He did not even use a comp that sold on the same block that was smaller, and sold recently for 380k. The house was underappraised, and now they are stuck and it is a dead deal. Meanwhile the homeowners don't know what to think. HVCC is killing this business.

  • DaveGrady

    Good appraisers will walk away from HVCC and leave the culls who are already in there hurting seniors with bad valuations. The lender UWs are devaluing homestead property appraisals and violating the law while they do it. Seniors don't get to see the appraisal they paid for in most until the closing which prevents them from making clear decisions on whether the reverse is a good thing for them. Add to that the huge number of seniors who will walk away from reverse because they cannot pay for an upfront appraisal cost (a discriminatory policy) and it becomes an unworkable process. Every LO/Broker and Appraiser needs to be screaming at the top of his/her lungs to their congressional folks that they have lost their vote until this thing is fixed. You'd think the media would have picked up on this months ago.

  • DaveGrady

    Merry Christmas!!
    Important FHA Changes

    HUD is delaying Mortgagee Letter 209-28, Appraiser Independence until February 15, 2010. Mortgagee Letter 2009-28 was originally planned for January 1, 2010.
    The original Mortgagee Letter has two parts: a) prohibition of mortgage brokers and commission-based lender staff from the appraisal process, and b) appraiser selection in FHA Connection.
    The effective date for both sections of this Mortgagee Letter will now take effect for all case number assigned on or after February 15, 2020. This extention will provide FHA and lenders additional time to adjust systems to accommodate the changes.
    Detailed instructions on changes to FHA Connection will be issued in a new Mortgagee Letter.

    In addition, HUD is delaying Mortgagee Letter 2009-51 which adopts the Appraisal Update and/or Completion Reports. The effective date will now apply to all case numbers assigned on or after February 15, 2010.

  • Retired Appraiser

    As predicted we are beginning to get a glimpse of the HVCC program; a double dip into recession led by another housing slump. It's not like we couldn't predict it. Run experienced appraisers out of the business and rely solely upon freshly trained experienced appraisers who have never seen a recession much less a major housing decline.

    I hate to say I told you so but I've been predicting this for over a year. Enjoy your new recession Andrew. It's only a matter of time before it's traced back exclusively to your greedy little scam.

  • El

    I have a question. I was considering building a custom home, which I couldn't afford with a conventional mortgage. I was told by the builder that since I am over 62 and have no heirs, a reverse mortgage would work well for me to pay off this new home. The bulder said that the appraised value would increase between the construction loan and the mortgage, so the lump sum from a reverse mortgage would pay off the home. I'm not convinced that a reverse mortgage was designed to buy something one can't otherwise afford and I decided not to go ahead because it all seemed too risky for my retirement, but I haven't been able to find out the answer to my basic question. Is it true that the appraised value of a custom built home automatically increases between the start of the construction loan and the conversion to a mortgage?

  • El

    I have a question. I was considering building a custom home, which I couldn’t afford with a conventional mortgage. I was told by the builder that since I am over 62 and have no heirs, a reverse mortgage would work well for me to pay off this new home. The bulder said that the appraised value would increase between the construction loan and the mortgage, so the lump sum from a reverse mortgage would pay off the home. I’m not convinced that a reverse mortgage was designed to buy something one can’t otherwise afford and I decided not to go ahead because it all seemed too risky for my retirement, but I haven’t been able to find out the answer to my basic question. Is it true that the appraised value of a custom built home automatically increases between the start of the construction loan and the conversion to a mortgage?

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