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Cuomo Makes Progress In Appraisal Disconnect Problem

February 26, 2008 | 9:11 am | |

New York State Attorney General Cuomo is close to striking a deal with the two mortgage GSE’s Fannie Mae and Freddie Mac to instill some separation between the quality and sales function of banks that do business with them. Although this was initiated by New York, the deal would have ramifications for all lenders of conforming loan products that sell their mortgage paper.

Its not a done deal yet but its being reported as “close” by the Wall Street Journal’s Amir Efrati in this morning’s article Deal Nears to Curb Home-Appraisal Abuse. Here’s my contribution:

Jonathan J. Miller, a veteran New York appraiser and longtime critic of industry practices, said the proposed deal “sounds like a promising step, and that Mr. Cuomo’s office is addressing some of the key problems that appraisers have had to deal with and that have led to the disconnect between value and risk in the mortgage markets.” He estimates that home values are overvalued nationwide by at least 10% because of inflated appraisals.

My 10% estimation is very conservative and was based on my New York area experience and interactions with colleagues across the country.

Reuters and American Banker have also issued stories on the negotiations.

The deal proposes the following actions by Fannie and Freddie:

  • They will not do business with lenders that use in-house appraisers.
  • They will not buy mortgages from lenders that who use appraisals from wholly owned subsidiaries. (I believe this would apply to Landsafe, Countrywide’s Appraisal Management company).
  • Require lenders not to use appraisals arranged by individual mortgage brokers.
  • Create a clearinghouse for appraiser information and provide reports to the public.

Note: I will be updating this post throughout the day – the ramifications are huge

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Finally, A Different Appraisal Pressure, And Its A Good Thing

November 4, 2007 | 12:05 am | | Public |

Back in June of 2005, I was interviewed by Bob Moon of American Marketplace. I was very PO’ed about the pressures placed on the appraisal profession because the structure (the relationship between the independence of the appraisal process and mortgage origination) was inherently flawed. About a month later I launched Soapbox as well as Matrix and the interview became my first post.

This past Friday, several people told me about an NPR radio piece called: Inflated home appraisals? Rings a bell where they referenced my warning of two years ago.

It was back in June of 2005 when we heard from a leading property appraiser in New York City, Jonathan Miller. He told us lending institutions were colluding to get people loans that they were going to have big trouble paying back.

New York State Attorney General Andrew Cuomo’s office is suing eAppraisiIT, the appraisal management company, for yielding to reported pressure from Washington Mutual (‘WaMu’) to inflate appraisal values. (Apparently the AG can’t sue WaMu because the bank is federally chartered.)

This is action is unprecedented, and Cuomo suggests there are more cases to follow. In fact, the Office of Thrift Supervision [OTS] is getting in on the action which suggests a turf war may even develop as the states took more vigorous action before the feds did.

Kevin L. Petrasic, managing director of external affairs for the Office of Thrift Supervision, the Treasury Department agency that oversees Washington Mutual, says the agency is “looking into the allegations that were put forth in the [New York] complaint.” He added that it “concerns us” that the attorney general “had information that consumers were not protected…but didn’t bother to contact the federal regulators. Isn’t that the whole point of regulation?”

Whether or not the parties in this particular case are guilty, the complaint drafted by the AG’s office is one of the best presentations of how portions of the lending industry think of the appraisal profession and how the appraiser is readily placed in a position that compromises their neutrality.

You gotta pay to play” becomes “You gotta play to get paid.”

If you want to understand the topic of appraisal pressure, the following documents are a must-read:

NYS AG Cuomo Press Release
AG Complaint against eAppraisIT [essential reading – pdf]

The AG Complaint is very well written. It lays out the systemic problem of appraiser independence in a clear and logic way. I feel its essential reading for everyone involved in real estate in some capacity.

It’s going to be interesting to see how the AG tries to prove that the defendant actually carried out its client’s wishes and was guilty of systematic fraud (i.e. the appraiser intentionally appraised a property 7 or 8 or 10% too high). This particular measurement is the key metric required to flush out this fundamental problem.

While I don’t work for either of these two companies and therefore cannot comment on their guilt or innocence, I can say, in the larger perspective, that it is refreshing that something is finally happening to on the appraisal pressure front. The appraisal profession is not flashy, has limited lobbying influence in Washington and is not very well understood by the public. It is also not well compensated, and yet it is at the center stage in the mortgage-origination process where trillions of dollars are at stake.

WaMu used to have an in-house appraisal review function that served to insulate appraisers from the pressures of the sales function within the bank. Last year, however, in a cost cutting move, Miller Samuel, as well as many other independent appraisers, lost WaMu as a big client when they closed all their in-house review functions and went with appraisal management companies, eAppraisIT and Lenders Service.

As evidenced by the charges, it would appear that this change called into question the independence of the appraisal process exposing it to more pressure, especially given this situation in which 267,000 appraisals per year from one client were at stake. That’s the proverbial “all eggs in one basket” scenario and places such a large firm even more dependent on the whims of a client, not less as WaMu suggests.

The $50,000,000 in appraisal fees paid out by WaMu at that volume level, makes the average appraisal fee $187.27. Combine this with a 48 hour turnaround time and I start wondering about quality.

WaMu has stated that they have no incentive to pressure appraisers. While I am not passing judgement on WaMu, I don’t see how that’s possible when the risk inherent in the mortgages can be offloaded to unwitting investors. As Floyd Norris mentions in his blog:

But maybe, just maybe, it is not a good idea to arrange for a lender to have no stake in whether the loan is repaid.

Certainly a big part of the unwillingness on the part of the secondary market investors are reluctant to buy any mortgage paper right now is a direct function of their skepticism about the credibility of the appraisals underlying the loans.

After the dot-com bubble crash in 2000, investment banks were forced to erect much tougher “Chinese Walls” to insulate equity analysts from the pressures of investment banking clients who could only imagine that all their stocks were a ‘buy’ and never a ‘hold’, much less a ‘sell’. Maybe this is an important precedent for the mortgage lending industry if they want to (or are told that) they must reestablish the credibility of the appraisal function.

Check out:

The Trouble With Appraisals [New Developments Blog – WSJ]
New Headache For Homeowners: Inflated Appraisals [Page One – WSJ]
WaMu faulted on home loans Colluded to inflate property values, N.Y. attorney general says [SeattlePI]


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Another Appraisal Firm Enters Pressure Realm + 20,000 Reports

June 11, 2007 | 12:01 am | |

This is getting interesting.

Vanderbilt Appraisal Company LLC, the second of our two major competitors, was subpoenaed last week into the widening probe over mortgage brokers pressuring appraisers by New York State Attorney General Andrew Cuomo.

The news coverage has been particularly heavy, likely because the firms being subpoened cover the most expensive real estate market in the US. The irony here is the fact that this investigation stemmed from subprime lending practices, of which there is a limited amount in New York City. And of course, a subpoena doesn’t infer guilt.

Appraisal pressure is a key ingredient in the problem with the mortgage industry being uncovered today and I am glad it is getting the attention it deserves. Just talking about it helps bring the problem to the forefront. There’s been a lot of news on the topic in the past week:

And in Ohio…
The Ohio Attorney General filed suit against seven mortgage brokers, 2 lenders and an appraiser last week:

A related aside (is there such a thing?)
I was struck by a specific number in the Bloomberg story that was so over the top, I wanted to mention it. Bloomberg reported that the two principals have personally done over 20,000 appraisals. However, their web site actually says that number applies to one of the principals who has personally performed more than 20,000 appraisals since 1991. The site also reports that the other principal has done about 15,000 reports over what I assume to be the same period.

If I do the math with the first principal, that is the equivalent of one person doing 20,000+ appraisals/16 years/50 weeks per year (assume a vacation)/5 days per week (assume time with family on weekends) equals 5 full appraisals from start to finish per day while owning, running and growing a regional appraisal business that includes New York, New Jersey, Connecticut and Florida.

Thats about 4x the number I have personally appraised since 1986 (in 5 more years).

Now thats time management!


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[Sounding Bored] The Power of Yes! WAMU Pulls The Plug On All Residential Appraisal Department Employees

July 12, 2006 | 2:03 pm |

Sounding Bored is my semi-regular column on the state of the residential appraisal profession. Today I discuss the massive layoff of the appraisal department by WAMU effective September 12th.

Effective September 12, 2006

Washington Mutual Bank, affectionately called the bank of last resort by its own employees (making fun of its Power of Yes ad campaign), told its employees today that they are discontinuing the in-house appraisal department. Going forward, all residential appraisal functions will be managed by First American and Lender’s Service, two appraisal management companies. (Disclaimer: My appraisal firm has worked for WAMU since the early days and choose not to work for the AMC’s.)

This action finally puts the issue to rest.

The appraisal department had been one of the few remaining of the national lenders that actually looks at the reports that come in, to assess the collateral for their loans. Its been an automated slow bleed after the last two series of major layoffs.

Things were never the same after upper management botched the installation of their in-house appraisal management system called OPTIS VALUE, that never really worked. OV was the in-house back end version of AppraisalPort (which worked fine). Most upper management associated with the decision and implementation effort were purged.

The last 5 years has been a clerical nightmare for all. WAMU could never figure out how to make it work effectively. It looks like they admitted it was a failure.

The appraisal staff that currently works at WAMU are good people given limited resources to review the heavy flow of reports that come through their pipeline.

Its absolutely amazing that a federally insured financial institution could be allowed to let an appraisal management company handle the appraisal function. AMC’s are a low margin business who rely on appraisers who generally work for less than half the market rate and therefore can not afford data sources nor the time to verify information. They are essentially there to fill out a form for the file and are rated for turn times, not quality. I have opined about this on many occasions.

The timing for WAMU couldn’t be worse. The real estate market is softening and the pressure on appraisers to make the number is stronger than ever. I think I’d sell their stock if I had any.

I was hopeful that upper management would “get it” when they took over, but it looks like they don’t. I wonder what all those secondary market investors are going to think about the quality of WAMU mortgage portfolios going forward.

I’d call that the Power of No!

UPDATE: All vendors are being turned off on July 31st. The work will move to the AMC’s (40,000 appraisals per month). Can you imagine the deterioration in quality for investors thats going to happen right away? Rumor has it that WAMU is being prepped for a sale to another lender and another 6,000 layoffs are planned. Citigroup has been in the rumormill as a takeover candidate for the past several years. Since Citi uses these AMC’s, it makes sense.

UPDATE 2: Here’s a t-shirt link for those affected sent by a number of ex and future ex WAMU employees [Warning – may offend].

UPDATE 3: WAMU Thanks All Their Residential Appraisers For Doing Such A Great Job And Now Will Let Them Spend More Time With Their Families [Soapbox].

UPDATE 4: According to American Banker, WAMU had 30,336 employees as of March 31, 2006, up 10% from the prior year.


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Appraisal Pressure Applied By Unwitting Clerical Staff: Appraisers Are Seen As Snails

November 18, 2005 | 10:51 pm |

Today we got an email from a client contact that read:


From: ############
Date: November 17, 2005
To: XXXX@millersamuel.com>
Subject: RE: Status

why does it take your office  1- 1 1/2 weeks to write up a report!?

This email was sent by an appraisal management company, who took over a long standing account that handles high end properties. They have been mandated to use our firm. Of course, you have to remember that we provide our service in a market where 80% of the housing stock is not a matter of public record, and we have no MLS system. To my knowlege this AMC does not review quality (or at least substantively) and simply track their vendors by turn times.

Its an ongoing battle with this client and eventually, the original bank’s loyalty, which has protected us from the AMC’s pressure, will fade as time passes since the original client doesn’t interact with us directly anymore.


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A Disputed Possible Solution To Appraisal Disputes

October 26, 2005 | 9:32 am |

We have outlined in great detail within Soapbox, that appraisal pressure is prevalent in the lending industry, encouraged by the structure of the lending process and the lack of political clout held by the appraisal industry.

A consumer activist group National Community Reinvestment Coalition has set up a trade group to arrange for the arbitration of business disputes over appraisals [American Banker]. “Members of the Center for Responsible Appraisals and Valuations would also agree to follow a “code of conduct.” They would include all parties to the process – lenders, appraisers, and various intermediaries.”

Here is the NCRC press release. [PDF]

One of the issues the lending industry has problems with, and rightly so, is that in a mortgage situation, the appraisals is being done for the lender, not the borrower. However, the problem with this structure, is that the lender is not incentivised to weed out appraisers that are there strictly to make the deal. Problems usually occur years down the road. Lack of focus on competency is clearly evidenced by the proliferation of appraisal factories (very large shops largely manned by trainees) and appraisal management companies who largely measure appraisal quality by turn around times.

Curently, lenders typically sue the appraiser’s E & O insurance company which is difficult because the insurers are in the business of litigation and its often difficult to extract claims.

I believe the objective here is to improve the reliability of appraisals. Since appraisal licensing came into effect in 1991 through FIRREA, the focus has been on licensing, required coursework and continuing education.

However, the reality is that licensing has been ineffecive because the states, who are charged with administering their interpretation of the federal law, have limited budgets and minimal staffing. Even if they did have adequate staffing, is a state agency really in the position to determine whether the appraiser used reasonable comps? I don’t believe so.

Erick Bergquist, the author of the American Banker article provides a quote from a lender:

[A National Lender’s] spokeswoman said Tuesday that appraisals are “something we already have some pretty stringent guidelines around and monitor on an ongoing basis.” As a result, “we really haven’t seen a big issue.”

This is the typical lender response to this issue which shows how, in rising markets, there are generally no problems since the deals usually get done. Stringent guidelines usually refer to more quantifiable requirements that generally do not impact quality. Its very difficult to measure quality and therefore most emphasis is placed on turn times. For a lender to say there is really no issue, really is the issue.

Perhaps the outcome of this effort will be to create additional awareness of the problem, but I doubt it will be universally accepted by the lending industry. It has to be for this to be universally accepted. However, I believe it is a step in the right direction.


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August 9, 2019

Rocky Raccoon Houses A Strong Desire For Stuff

Sometimes people want what they want, no matter what the risk is. There is a lot of that same sentiment coming from regulators and policy administrators in the federal government these days. More on that in future editions of these Housing Notes, but until then, we’ll fight for our jackets.

On an unrelated note, here’s a shoutout to my excellent summer semester Columbia grad students in the GSAPP program who took their final exam yesterday. I really enjoyed the class interaction and wish them well in their careers. When turning in their completed exam, one of the students commented that they specifically enjoyed my discussion on pie versus cake

Oh, the satisfaction of teaching can not be put into words!

But I digress…

Rate Talk: Business versus Consumer Sentiment Is Like Apples versus Oranges

As I’ve mentioned before in these housing notes, the bond market seems terrified of current U.S. economic policies while the stock market seems euphoric (even though the stock market is not the economy.

Sam Khater, Freddie Mac’s chief economist, and aficionado of the only band that matters says, “There is a tug of war in the financial markets between weaker business sentiment and consumer sentiment. Business sentiment is declining on negative trade and manufacturing headlines, but consumer sentiment remains buoyed by a strong labor market and low rates that will continue to drive home sales into the fall.”

I loved this observation about sentiment (and The Clash, obviously).


Chart-Nirvana Market Update In Elliman Magazine

As regular readers of my Housing Notes have noticed, I create a full-page spread for Douglas Elliman Real Estate’s quarterly magazine using the results of my U.S. market research. I’m no Len Keifer but still, the visuals are pretty cool.

A Potential Spike In Refi’s, Illustrated

Here’s a good look at the refinance situation via The Basis Point, always a good read. The one point not made here is that falling rates raise prices which is not good for housing in the long term when matched against tepid wage growth. The drop in rates is a short term win for consumers, not a long term win.

Vox: Where Manhattan’s Street Grids Came From

It wasn’t by accident.

Spurious Housing Correlations: Grocery Stores

Here’s one from ATTOM.

  1. Take a ton of housing data and geotag it for its proximity to a grocery store like Whole Foods (a.k.a. Whole Paycheck) or Trader Joes.
  2. Then measure the value of a neighborhood against those farther away or before and after the store was built.
  3. Base the analysis on zip codes even thought zip codes don’t represent neighborhoods or like housing stock.
  4. And you get…voila…junkstats.

There are so many other factors to be considered that this type of analysis is way too simplistic to be credible. An example of spurious correlations in my housing market of Manhattan would be to compare the average or median sales price of an apartment with or without a fireplace. Homes with fireplaces tend to be “pre-war” (built prior to WWII) or penthouses which sell for a premium above the remainder of the housing stock. My own fireplace amenity analysis was not some sort of boolean logic exercise found in the ATTOM analysis.

Bloomberg Terminals: Miller Samuel Luxury Housing Index

We power 6 different price indices for Manhattan luxury housing on the Bloomberg Terminals. This luxury median sales price chart shows how the market has slid from recent highs and how much prices have surged after the financial crisis.


Downtown Alliance: Q2-2019 Lower Manhattan Market Overview

For many years I’ve been crunching residential housing data for the Downtown Alliance for use in their quarterly reports. Here are the residential pages of their latest report:



Appraiserville

(For earlier appraisal industry commentary, visit my old clunky REIC site.) As I said last week, I’m taking a bit of a summer hiatus from appraisal policy discussions, but there is always time for this:

Appraising Unique Properties Like Attached RV Garages

I’ve been at this appraisal thing for 33 years and I’ve never seen or heard of this amenity or the targeted demo it appeals to. My friend and appraiser colleague Ryan Lundquist is the undisputed leader of wacky amenity observations.

OFT (One Final Thought)

Aside from his dirty hands, this would be a typical experience in my kitchen. The skills demonstrated here are strangely satisfying and are required viewing.

Brilliant Idea #1

If you need something rock solid in your life (particularly on Friday afternoons) and someone forwarded this to you, or you think you already subscribed, sign up here for these weekly Housing Notes. And be sure to share with a friend or colleague if you enjoy them because:

  • They’ll replay the Beatle’s ‘White Album” for that ‘Rocky Raccoon’ song;
  • You’ll learn to love my charts;
  • And I’ll go to the grocery store.

Brilliant Idea #2

You’re obviously full of insights and ideas as a reader of Housing Notes. I appreciate every email I receive and it helps me craft the next week’s Housing Note.

See you next week.

Jonathan J. Miller, CRP, CRE, Member of RAC
President/CEO
Miller Samuel Inc.
Real Estate Appraisers & Consultants
Matrix Blog @jonathanmiller

Reads, Listens and Visuals I Enjoyed

My New Content, Research and Mentions

Appraisal Related Reads

Extra Curricular Reads


June 21, 2019

From Pink To Purple: Get Ready For The Housing Ride of Your Life

While I love rollercoasters, I am not of fan of anything that spins, plunges or inverts (translation: anything besides fast old school wood rollercoasters). I turn green very easily when sitting in a car anywhere but the driver’s seat or even answering/texting on my iPhone when I am a passenger.

I am already beginning to turn green: The Fed may cut rates by a half percent over the summer, economic and foreign policies including “tariff talk” out of Washington seem to get more random every day and the GSEs are looking to “modernize” the mortgage process by transitioning to Zestimate-like valuations.

But I digress…

Disclosing Non-Disclosure States


[WSJ/Mike Lemanski]

There are a dozen non-disclosure states in the U.S. with differing levels of restrictions. The idea behind the disclosure of real estate transactions is to promote a fair and open market in order to protect the consumer. I assume that the non-disclosure states were the result of a combination of concerns about the privacy of data and a powerful real estate lobby back when real estate brokers were the gatekeepers of housing data. Whatever the reason, today’s housing market demands more transparency whether the data is disclosed legally or not.

We are seeing a bunch of what looks like illegal disclosure activity in states where the MLS data is pumped out into the public domain by data aggregators (who will be doomed in the future anyway by the advent of blockchain). Institutional users of this aggregated data are often unaware of the illegality of it. A widely publicized case of this was when the Austin MLS accused CoreLogic of selling of illegally obtained data to tax appraisers. While I get the Realtor’s concerns with the basis of the illegality of the data it’s hard to wrap my mind around the higher valuations claim since there should be randomness in the data released.

The board is concerned that as a result, appraisals could rise significantly since Travis Central Appraisal District had access to the fresh sales data from the MLS.

This seems like an odd reason (aside from the illegality) to fight for i.e. “We Want Old Data for Tax Purposes!”

Yield To The Curve!

We’ve been discussing the flattening/inverted yield curve for months now so perhaps we can declare a downturn, possibly a recession, is imminent. With consensus building for drastic rate cuts this summer, it’s worth taking a look at the topic more closely.

My friend Hugh Kelly of Hugh F. Kelly Real Estate Economics who taught at NYU/Schack for more than three decades and now is the director of graduate programs & chair of the executive advisory council curriculum committee at the Fordham University Real Estate Institute among other things, wrote a compelling column in the latest issue of Commercial Property Executive: Economic View: Why You Should Watch the Yield Curve:

A couple of key insights

“If the unemployment rate is back to where it was in 1969, we should remember that this was the beginning of the Baby Boomers’ entry into the job market, and that we are now in the early years of the Boomers’ exit.”

“That interest rate wave—with many consumer credit rates and mortgages pegged to short-term benchmarks—is still an economic indicator worth attending to. As history tells us, inverted yield curves presage liquidity squeezes, and that’s why inversion is considered an advance indicator of recessions.”

“As of this writing, approximately 20 percent of the bonds being traded around the globe bear negative interest rates, according to World Bank data.”

Little Pink Houses: Downtown Single-Family Housing Is No Longer Sustainable

The common sense rationale here spoke to me and it’s gaining momentum. This was a fascinating listen (and read).


The New York Times presents a compelling visualization on the topic as well: Cities Start to Question an American Ideal: A House With a Yard on Every Lot

Single-family zoning is practically gospel in America, embraced by homeowners and local governments to protect neighborhoods of tidy houses from denser development nearby.

But a number of officials across the country are starting to make seemingly heretical moves. The Oregon legislature this month will consider a law that would end zoning exclusively for single-family homes in most of the state. California lawmakers have drafted a bill that would effectively do the same. In December, the Minneapolis City Council voted to end single-family zoning citywide.



[NYT]


[NYT]

Forget Pink Houses: Purple Rain Leads To A Purple Driveway

Think Minneapolis, the hometown of Prince and Purple Rain. Now, take a look at the driveway at his Turks & Caicos estate. In fact, the whole layout of the property is simply amazing.


[WSJ]

Appraiserville

(For earlier appraisal industry commentary, visit my old clunky REIC site.)

OCAP Shows The Nation What An Appraiser Coalition Can Do

This week I flew to Ohio to speak at the Ohio Coalition of Appraiser Professionals (OCAP)‘ Conference that was smack in the middle of the Ohio State campus in Columbus Ohio. I interact with a lot of state coalitions and OCAP is one of the best. I was asked back despite last year’s proud mention of my Michigan State University pedigree amongst a sea of red and white clothing. I squeezed in a few Spartan mentions this time and aside from the boos and hisses, the attendees were true professionals. I really enjoyed interacting with everyone there and the organization is one of the strongest coalitions I’ve seen. I got to speak one on one quite a bit with industry legend Larry Disney, connected with Anne M. Petit, Superintendent Ohio Division of Real Estate & Professional, whose good work is heard all the way back in New York, my friend Phil Crawford of Voice of Appraisal who literally brought tinker toys to a whole new level via blockchain and my friend and fellow Relocation Appraisers & Consultants (RAC) member Ernie Durbin, the Chief Valuation Officer at Clarocity who walked attendees through regulatory, technology and scope changes. I got to spend some time with my friend Jamie Owen of the Clevland Appraisal Blog as well. The “sausage party” photo with Ernie and Phil was an inside joke from last fall’s Appraiserfest conference led by Phil that took place in San Antonio.




Kudos to the OCAP leadership for coordinating such an invaluable event.

Code For Appraisal Modernization: Changing Smart Lightbulbs

This video provides the perfect analogy for the misrepresentation of what appraisal “modernization” actually means. The image conveyed is a smooth simple process that involves a few buttons. Whenever the modernization topic is discussed, residential appraisers are not asked to the table yet they are the only valuation experts that have “on the ground” expertise.

I challenge you to listen to the entire 3-minute video without losing your mind.


NEW NORTH DAKOTA WAIVER REQUEST The Most Important Issue Facing The Appraisal Industry RIGHT NOW

If you thought the answer was the House “modernization” panel discussion that occurred in front of the House Financial Services Committee this week you were wrong.

The state of North Dakota is attempting to obtain another waiver request, not the laughably written request of last summer. Now North Dakota is requesting a waiver for five years!

From the Federal Register

The request seeks a waiver of appraiser credentialing requirements for appraisals for federally related transactions under $500,000 for 1-to-4 family residential real estate transactions and under $1,000,000 for agricultural and commercial real estate transactions throughout the State of North Dakota for a period of not less than five years.

Translation

Lenders don’t want to pay market rate fees so why not have bank employees make the numbers up. What could go wrong? Here is the anti-appraiser propaganda web site CSBS that somehow ignores this point. Perhaps next time the North Dakota governor will sign off waiving licenses for doctors because there aren’t enough? This is an economic issue plain and simple.

This request was filed on May 30th with a 30-day notice for comment. Time is running out! ASA has a landing page for appraisers (and anyone else) to provide comments. There is a public hearing on July 9th (I wish I could attend but I am providing expert witness testimony that day) so please try to attend. It will make a difference when the regulators see our industry’s concern.

ASC Notice for Comment – North Dakota Temporary Waiver Request

This places the taxpayers on the hook for the aftermath and is an insanely irresponsible request to make given the global financial crisis we just went through. History is repeating itself. Appraisers need to get the word out!

Hearing: What’s Your Home Worth? A Review of the Appraisal Industry

Last week I mentioned that I didn’t make the cut to represent independent boots-on-the-ground appraisers but was appreciative of being acknowledged by the committee for reasons I’ll discuss at a later date.

The feedback from the appraisal industry after the session was how large the misunderstanding of what appraisers actually do. Perhaps that’s why the current conditions and perceptions exist – on-the-ground residential appraisers are never invited to the table to clarify what’s really happening. I hope the committee now feels the same way after viewing the remaining self-serving testimony. While it was good to have a discussion, the idea that appraisers make the market is simply detached. As I’ve said many times: The Market Doesn’t Care What You Think.

Here’s a breakdown of the five invited panel members,

Dave Bunton, The President of The Appraisal Foundation spoke about the importance of independent valuation and the reasons why professional appraisers protect the public trust and the consumer. The Appraisal Foundation is a non-profit organization with congressional authority (Title XI of the Financial Institutions Reform, Recovery and Enforcement Act, of 1989) (Title XI) to establish minimum qualifications for licensed and certified appraisers and promulgate the Uniform Standards of Professional Appraisal Practice (USPAP).

Stephen S. Wagner, Commercial Appraiser, on behalf of The Appraisal Institute. Sadly, he represented an organization that doesn’t care about residential appraisers or consumers as noted by their faster rate of membership decline than credentialed appraisers. The Appraisal Institute is a private trade organization which grants the MAI designation. AI has no legal authority at any level except over its membership. As an example of their anti-consumer stance, AI was instrumental in aggressive lobbying to pass California SB-70 which states: (C) States that there may be assumptions that the appraiser has not verified that may significantly impact the appraised value of the subject of the report. NOTE: With the wording of this bill, any appraiser could take any point of view and not back it up with verifiable data. For example, an appraiser could take a seller’s word on potential uses of their property and the appraiser can simply restate them and not provide any support to verify the claims. Stephen was on the residential committee that was thrown together by current director Jim Amorin in hopes assuaging the masses after I spoke early and often for their members who were outraged at the national organization’s efforts to seize local chapter funds. Two years later, they didn’t do anything for their residential members showing what an effort of misdirection it truly was. In fact, the appraiser outrage of the past 2.5 years directed towards the Appraisal Institute was triggered by the prior version of this committee in the fall of 2016 when the GOP controlled the house. Appraisal Institute is very much in favor of appraisal management companies and has former top executives installed in AMC companies.

Jeff Dickstein, Chief Compliance Office, Pro Teck Valuation Services, on behalf of The Real Estate Valuation Advocacy Association (REVAA). He represents the organization of appraisal management companies (AMCs) that is literally the reason why we have problems with the appraisal system today. REVAA is the advocacy group for the Appraisal Management Company (“AMC”) industry. They fight transparency and advocate for dropping licensing and certification requirements They represent a system that has decimated appraisers by leaching off their fees, created scope creep to justify their existence and pushed the completely false “appraiser shortage.” They represent problem number 1 to the valuation industry.

Andre Perry, David M. Rubenstein Fellow, Metropolitan Policy Program, The Brookings Institute whose work I am not familiar with but his research comprised half of the panel testimony time.

Joan N. Trice, Founder, Collateral Risk Network. Joan was a last minute addition as a previous panelist had a scheduling conflict. Joan attempts to speak for appraisers but makes her living by holding conferences for appraisal management companies so she is not neutral. She can’t have it both ways. She was the only panelist not to read her statement which was pro-appraiser and instead talked about other things almost as a time-killer. It was weird to have a panelist not read their statement. Any thoughts on why? Someone pointed out to me that she referred to the three approaches to value as “income, cost and market” then later called that last one the “sales price approach.”

Thoughts on future panel hearings:

The best source of any of this information is the various state coalitions, which rose out of the leadership void in the appraisal field. Given that the Appraisal Subcommittee and the Appraisal Foundation cannot lobby, State Coalitions are the best and most grass-roots organizations out there.

OFT (One Final Thought)

Please remember this when taking at face value the long term predictions of prognosticators.

Brilliant Idea #1

If you need something rock solid in your life (particularly on Friday afternoons) and someone forwarded this to you, or you think you already subscribed, sign up here for these weekly Housing Notes. And be sure to share with a friend or colleague if you enjoy them because:

  • They’ll be wrong about the future;
  • You’ll sell your pink house;
  • And I’ll purple my driveway.

Brilliant Idea #2

You’re obviously full of insights and ideas as a reader of Housing Notes. I appreciate every email I receive and it helps me craft the next week’s Housing Note.

See you next week.

Jonathan J. Miller, CRP, CRE, Member of RAC
President/CEO
Miller Samuel Inc.
Real Estate Appraisers & Consultants
Matrix Blog @jonathanmiller

Reads, Listens and Visuals I Enjoyed

My New Content, Research and Mentions

Appraisal Related Reads

Extra Curricular Reads


February 15, 2019

Amazon To NYC Housing Market: “Drop Dead!”

A recent headline in the Commercial Observer said it best with a possibly NSFW awesome graphic. The Amazon pull out was all the news rage since Thursday afternoon. I’ll discuss this further down in these Housing Notes and provided a list of links down at the bottom for the Amazon HQ2 situation.

In the meantime, this is what my work week felt like. I was trying to move fast and things kept slowing me down that I didn’t expect:

View this post on Instagram

omg

A post shared by DAFNE FIXED (@dafnefixed) on

Elliman Report Released: January 2019 – Manhattan, Brooklyn & Queens Rentals

As the same time there was all the hoopla on the Amazon decision to walk away from their deal with NYC, Douglas Elliman published our research on the rental market of the Long Island vicinity as well as Manhattan and Brooklyn. This is part of our expanding Elliman Report series I’ve been authoring since 1994.

Elliman Report: 1-2019 Manhattan, Brooklyn & Queens Rentals

First of all, Bloomberg News coverage of the Manhattan rental market gave me a “twofer” in the chart department. And you all know how much I love charts.

But there’s more chartage..

…from Dow Jones:

The Wall Street Journal…

…and Mansion Global…

…and The Real Deal bedazzled the existing chart in our report…

And some of our charts:

NYC Rental Market Talking Points by Region

Manhattan Rentals

“The market share of landlord concessions declined year over year, after forty-three consecutive months of increases.”

– The use of concessions may be peaking as more potential homebuyers move into the rental market, helping push rents up
– Median rent growth accelerated in larger apartments as a shift to higher quality stock continued
– The year over year market share of landlord concessions falls after forty-three consecutive months of increases
– Vacancy rate fell year over year for the eighth consecutive month
– Non-doorman median rent outperformed doorman median rent for the first time in six months
– The entry threshold increased in line with luxury price trend indicators

Brooklyn Rentals

“The market share of landlord concessions declined year over year, after thirty-five consecutive months of increases.”

– The use of concessions may be peaking as more potential homebuyers move into the rental market, helping push rents up
– Market share of concessions declined year over year after nearly three years of increases
– Market share of 1-bedroom rentals was the only segment to see a rise
– Median rent growth was most robust in smaller apartments

NW Queens Rentals

“With rising new development market share, increasing rental price trends continue to be influenced by the shift to higher quality new housing stock.”

– Face rents pressed higher as new development influx skewed prices upward
– Market share of concessions increased year over year for the fifth consecutive month
– Number of new leases increased year over year for a seventh consecutive month

Amazon Gone

On Thursday I was climbing up a ladder in an old Brownstone to access to roof area (hey, I’m an appraiser too) when my iPhone blew up. I got about 20 press calls in the subsequent two hours concerning the impact to the LIC and NYC residential market (see “Amazon HQ2” links at the bottom of these Housing Notes. Here are two call-ins I did (with my high school graduation-like photo) on Bloomberg (lol) – file photo was taken around 2003:

Yesterday:

This morning:


I’d pontificate more but the Bloomberg interviews above and the coverage of the real estate angle are included in the “My New Content, Research and Mentions” links below.

My friend Barry Ritholtz gets specific on where he thinks the blame lies for the Amazon decision in this thread…


How Big Is NYC Tech Versus Wall Street?

There was a terrific article in the New York Times related to the Amazon HQ2 deal collapse but it was more of an analysis of how the NYC economy is configured: Even Without Amazon, Tech Could Keep Gaining Ground in New York Seems like mandatory reading for anyone in NYC real estate.

I remember when Wall Street accounted for 23% of the pay, now it is down to 19%. Other sectors have stepped up to fill the void. Here are a few charts from the New York Times piece that give context to the tech and securities role in the NYC economy. Click on the graphics to read the article.


The Housing Bubble/Bust of a Decade Ago May Keep The Market From Repeating It

Bloomberg shared an interesting home sale process video that focused on the phenomenon of rising price AND rising inventory at the same time – not what we are seeing in this cycle.

New in the Real Estate Lexicon: Mosh Pit

The first time I’ve ever been able to use “mosh pit” in a real estate context but it somehow works in this Realtor.com interview:

After Amazon plucked it from national obscurity, it became “overhyped,” says New York City-based real estate appraiser Jonathan Miller. “There have been lots of stories about people buying three apartments sight unseen like there’s some sort of frenzy. … It’s not some sort of frenzy where people are in a mosh pit diving over each other to get the next apartment.”


Small Town Boom: The Indicator from Planet Money

The Indicator is a daily listen for me because its full of economic topics that relate to housing. This one discusses the topic of rural economies and how some rural towns are getting out of the classic failure spiral.

Bloomberg: Why America’s New Apartment Buildings All Look the Same

This was my favorite read of this week: Why America’s New Apartment Buildings All Look the Same I interviewed the author Justin Fox years ago on my old “The Housing Helix Podcast” and have always been a fan of his writing.

I’m not exaggerating when I say that each time I have visited a different U.S. city in the past five years, I always ask myself, “Is it just me or do all these rentals buildings look like all the rental buildings I’ve seen in other cities?” Examples include Boston, Washington, D.C., Dallas, Detroit, Chicago, San Francisco, Los Angeles, Philadelphia, Cleveland, Baltimore, Harrisburg, Wilmington, Annapolis, San Antonio, and Columbus to name a few. It’s crazy. And good grief, I am traveling way more than I thought.

When you look at these images in the Bloomberg story below, I’ll bet most of my Housing Notes readers have seen buildings like this EVERYWHERE.

China: 65 Million Empty Apartments

You think we have a lot of vertical (vacant) rental or condo housing units in the U.S. Take a look at the situation in China from this Nikkea Asian Review article: China’s housing glut casts pall over the economy – A building binge leaves cities with 65 million empty apartments

A few years ago my wife and I were in China and took a 5.5-hour high-speed rail trip from Beijing to Shanghai. During the trip, on both sides of the train, this was essentially the view (I took with my iPhone) Mile after mile of concrete midrise towers.

Upcoming Speaking Events

Appraiserville

(For earlier appraisal industry commentary, visit my old clunky REIC site.)

I’m light this week on appraisal issues due to the time devoted to the Amazon HQ2 pull out and its impact on the market over the past 24 hours. So I’ve provided a podcast and interview I gave with top real estate agents in their local markets who care about valuation and want to see our world accurately. These might provide some thoughts on how appraisers can explain the state of their profession and market to those outside the appraisal industry. I think many of us are good at writing about it but not necessarily articulating it. Elements of this will also apply to consumer interaction which is where future opportunities are. Here you go…

Sweat The Details Podcast: DUMBWAITERS, MARKET ANCHORS, CREDIBLE MARKET REPORTS

My longtime online friend Jim Duncan who is a Realtor and a Broker/Partner in Charlottesville, Virginia of Nest Realty. I’ve only met him once at an Inman Conference about 15 years ago but devotedly follow his online presence, especially his monthly note. He invited me to be interviewed with his colleagues on his new “Sweat The Details” podcast. It’s a 30-minute interview and I think they sped up my voice by 1.5 times to squeeze it into their 30-minute format. Hey, I have a lot to say! LOL.


The Apple Peeled – Ask the Experts: Market Dynamics with Jonathan Miller

Over the years, I have bantered with the Espinal Adler Team (Marie Espinal and Jeff Adler) at Douglas Elliman Real Estate about the market which has been invaluable for on the ground intel. And we’ve become friends. When Jeff and Marie asked me to be formally interviewed for their blog “The Apple Peeled” I was happy to do so, especially because I could veer off the road into issues about the current mortgage and appraisal process. This “The Apple Peeled” blog post: Ask the Experts: Market Dynamics with Jonathan Miller was distilled from the 90-minute conversation (I could have gone on for 5 hours) I had with their team.

I hope you find that this apple was fully peeled:


Jonathan Miller’s Market Outlook

The number of units sold in Manhattan in 2018 was down by more than 14 percent compared to the previous year. The brokerage industry tends to be very linear in its perception of the market, so many believe when the market is rising, it will rise forever. And, in-turn, when the market falls, it will fall forever. That approach can lead to overreaction.

The 10-year Challenge (2009 vs. 2019)

Some analysts are even comparing the current cycle to the last downturn and the housing bubble in 2009, but Miller outlined quite a few differences between then and now.

In 2009, the average discount from listing was 10.2%. In 2018 the discount was 5.2%. In ’09, Miller said sellers were anchored to the “pre-Lehman, pre-financial crisis asking prices” and had to travel farther on price to meet a buyer. (Miller measures listing discount by the percent difference between the contract price and the price that the property was listed for sale at the time of contract – not when it was first listed). The most recent asking price is “really the moment the property entered the market,” he said.

Miller said there are more buyers today compared to 2009, but those buyers are “very jaded about what value is.” Meanwhile, sellers are anchored to another market completely, he said.

The change in tax laws in 2018 and a several-month stretch that saw mortgage rates rise before recently dropping close to previous levels had both buyers and sellers re-calibrating what value is. That process can take time.

“If a seller overprices a listing, it takes them up to 2 years to de-anchor from what their price was without thinking that they left money on the table,” Miller said. “The disconnect between buyers and sellers is measured by lower sales volume.”

Starter Segment vs. High-End Luxury

For the last two years, Miller has said that the NYC market is softer at the top and tighter as you move lower in price.

Overall inventory is up by about 17%, with a significant amount of supply coming from the studio and 1-bedroom market. Studio inventory is up 21% percent.

“The pace of the starter market is still the fastest of all segments,” Miller said. “It’s just not as detached as it was because now you have more supply.”

Interest Rates and Their Impact

Typically, rates rise when the economy is strong. The low rates we’re seeing today understate the strength of the current economy, according to Miller. “That’s the disconnect.” In the long run, interest rates do not impact price trends. Mortgage rates have trended lower for three decades, Miller said, but housing prices have fluctuated up and down during that same lengthy stretch.

Mortgage rates weren’t wildly different in ’09 compared to today. In a recent report, Miller stated that an adjustable rate mortgage rate averaged 4.38% in 2009 and was at 3.98% using the same metrics in 2018.

Miller said that real estate investors should stop trying to perfectly time the market (both with rate and supply vs. demand). Perfect timing is a concept that was born out of the housing bubble, he said, when investors viewed housing as a highly liquid stock, instead of in its proper context. “(Real estate) is more of a long-term asset.”

In-Depth Look at the State of Appraisals

“There was nothing learned from the bad behavior of a decade ago,” Miller said, reminding himself of a Mark Twain quote. “History doesn’t repeat itself, but sometimes it rhymes,” Jonathan Miller recited. Miller, President and CEO of real estate appraisal and consulting firm Miller Samuel Inc., said federal regulators are acting irresponsibly in their effort to reduce and perhaps even eliminate the need for an appraisal as part of an overall effort to erase “friction points” that slow-down the mortgage application process.

Miller said the regulators were more concerned with collecting fees than they were with protecting the American consumer. He likened the subtle de-regulation to the housing bubble of a decade ago, pointing out that regulators were getting paid by the failing investment banks they were rating back then. Now, he said, regulators and both Fannie Mae and Freddie Mac are getting paid whenever loan volume passes through those agencies. (Fannie Mae and Freddie Mac are Government sponsored enterprises that purchase mortgages from banks and mortgage companies in an effort to create liquidity so that lenders have the capacity to lend to more homebuyers).

The Office of the Comptroller of the Currency (OCC), The Board of Governors for the Federal Reserve System, and the Federal Deposit Insurance Corporation (FDIC) proposed a rule to amend the agencies regulations requiring appraisals for certain real estate related transactions. The proposed rule would increase the threshold level at, or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.

In response to our request for comment, spokespeople for the FDIC, the OCC, and The Federal Reserve said they do not comment on proposed rules during the rulemaking process.

Mortgage volume has trended lower despite rates falling steadily since the housing bubble, because lenders don’t want to take on risk, Miller said. “They’re in the fetal position. Banks are afraid of their own shadow.”

The tremendous amount of regulation implemented since Dodd Frank has led to mortgage lenders filling Fannie and Freddie’s portfolios with low-risk “pristine” mortgage bundles. But with rates so low, margins are so compressed, regulators need to stimulate volume to make money, according to Miller. “I think (Fannie and Freddie) are emboldened to take more risk.”

The push for fewer mandatory appraisals isn’t the only thing that has hurt the appraisal industry since the Dodd Frank Act was passed in 2010. The evolution of the mortgage industry’s use of the Appraisal Management Company (AMC) has led to a collapse in quality of appraisals ordered by banks, Miller said. He described the AMC as an institutional middle man that takes more than 50 cents on the dollar away from the professional appraisers who do the actual work.

“It’s like a Hollywood actor paying their agent 60% instead of 10%,” Miller said. “The mortgage industry is trying to widgetize the appraiser.”

The AMC is supposed to act as a communication barrier between the appraiser and the loan officer or mortgage broker, to thwart undue pressure to bring appraised values in at specific numbers. But according to Miller, the AMCs are under the same types of pressure that an individual appraiser might face. Some AMCs receive hundreds of thousands of dollars every month by way of appraisal orders placed by big banks. At least at the sales level, the banks apply pressure to the AMC to not “kill deals,” said Miller, who has testified in several class action lawsuits against AMCs.

In many instances, Miller and his firm were hired to do sample reviews of appraisals that came through AMCs. Often, the AMC would utilize appraisers in the market that would always “hit the number,” Miller said. A lot of those appraisers were ignoring valid comps, sometimes from directly across the street that were virtually the same as the subject property. “The AMC encouraged it because they were getting the work,” he said.

Appraisers are pushing back and there are already signs that AMCs were beginning to crumble, Miller said. Quality appraisers are turning away bank work when they know the order is coming in through an AMC because they’re not happy working for less than they deserve and because they’ve been reduced to “form-fillers,” Miller said.


The Apple Peeled Blog, February 12, 2019

Espinal Adler Team at Douglas Elliman Real Estate

OFT (One Final Thought)

Well, this week’s OFT is more like (FFT) with 5 thoughts concerning volatility. The housing market is shifting gears and the economy may be doing the same. This infographic from the must-read Visual Capitalist site is fascinating:

Brilliant Idea #1

If you need something rock solid in your life (particularly on Friday afternoons) and someone forwarded this to you, or you think you already subscribed, sign up here for these weekly Housing Notes. And be sure to share with a friend or colleague if you enjoy them because:

  • They’ll be more volatile;
  • You’ll be taking inventory;
  • And I’ll get up early and talk on TV.

Brilliant Idea #2

You’re obviously full of insights and ideas as a reader of Housing Notes. I appreciate every email I receive and it helps me craft the next week’s Housing Note.

See you next week.

Jonathan J. Miller, CRP, CRE, Member of RAC
President/CEO
Miller Samuel Inc.
Real Estate Appraisers & Consultants
Matrix Blog @jonathanmiller

Reads, Listens and Visuals I Enjoyed

My New Content, Research and Mentions

Recently Published Elliman Market Reports

Amazon HQ2-NYC Related Reads

Appraisal Related Reads

Extra Curricular Reads


The Apple Peeled – Ask the Experts: Market Dynamics with Jonathan Miller

February 12, 2019 | 11:54 am | | Articles |

Over the years, I have bantered with the Espinal Adler Team (Marie Espinal and Jeff Adler) at Douglas Elliman Real Estate about the market which has been invaluable for on the ground intel. And we’ve become friends. When Jeff and Marie asked me to be formally interviewed for their blog “The Apple Peeled” I was happy to do so, especially because I could veer off the road into issues about the current mortgage and appraisal process. This “The Apple Peeled” blog post: Ask the Experts: Market Dynamics with Jonathan Miller was distilled from the 90-minute conversation (I could have gone on for 5 hours) I had with their team.

I hope you find that this apple was fully peeled:


Jonathan Miller’s Market Outlook

The number of units sold in Manhattan in 2018 was down by more than 14 percent compared to the previous year. The brokerage industry tends to be very linear in its perception of the market, so many believe when the market is rising, it will rise forever. And, in-turn, when the market falls, it will fall forever. That approach can lead to overreaction.

The 10-year Challenge (2009 vs. 2019)

Some analysts are even comparing the current cycle to the last downturn and the housing bubble in 2009, but Miller outlined quite a few differences between then and now.

In 2009, the average discount from listing was 10.2%. In 2018 the discount was 5.2%. In ’09, Miller said sellers were anchored to the “pre-Lehman, pre-financial crisis asking prices” and had to travel farther on price to meet a buyer. (Miller measures listing discount by the percent difference between the contract price and the price that the property was listed for sale at the time of contract – not when it was first listed). The most recent asking price is “really the moment the property entered the market,” he said.

Miller said there are more buyers today compared to 2009, but those buyers are “very jaded about what value is.” Meanwhile, sellers are anchored to another market completely, he said.

The change in tax laws in 2018 and a several-month stretch that saw mortgage rates rise before recently dropping close to previous levels had both buyers and sellers re-calibrating what value is. That process can take time.

“If a seller overprices a listing, it takes them up to 2 years to de-anchor from what their price was without thinking that they left money on the table,” Miller said. “The disconnect between buyers and sellers is measured by lower sales volume.”

Starter Segment vs. High-End Luxury

For the last two years, Miller has said that the NYC market is softer at the top and tighter as you move lower in price.

Overall inventory is up by about 17%, with a significant amount of supply coming from the studio and 1-bedroom market. Studio inventory is up 21% percent.

“The pace of the starter market is still the fastest of all segments,” Miller said. “It’s just not as detached as it was because now you have more supply.”

Interest Rates and Their Impact

Typically, rates rise when the economy is strong. The low rates we’re seeing today understate the strength of the current economy, according to Miller. “That’s the disconnect.” In the long run, interest rates do not impact price trends. Mortgage rates have trended lower for three decades, Miller said, but housing prices have fluctuated up and down during that same lengthy stretch.

Mortgage rates weren’t wildly different in ’09 compared to today. In a recent report, Miller stated that an adjustable rate mortgage rate averaged 4.38% in 2009 and was at 3.98% using the same metrics in 2018.

Miller said that real estate investors should stop trying to perfectly time the market (both with rate and supply vs. demand). Perfect timing is a concept that was born out of the housing bubble, he said, when investors viewed housing as a highly liquid stock, instead of in its proper context. “(Real estate) is more of a long-term asset.”

In-Depth Look at the State of Appraisals

“There was nothing learned from the bad behavior of a decade ago,” Miller said, reminding himself of a Mark Twain quote. “History doesn’t repeat itself, but sometimes it rhymes,” Jonathan Miller recited. Miller, President and CEO of real estate appraisal and consulting firm Miller Samuel Inc., said federal regulators are acting irresponsibly in their effort to reduce and perhaps even eliminate the need for an appraisal as part of an overall effort to erase “friction points” that slow-down the mortgage application process.

Miller said the regulators were more concerned with collecting fees than they were with protecting the American consumer. He likened the subtle de-regulation to the housing bubble of a decade ago, pointing out that regulators were getting paid by the failing investment banks they were rating back then. Now, he said, regulators and both Fannie Mae and Freddie Mac are getting paid whenever loan volume passes through those agencies. (Fannie Mae and Freddie Mac are Government sponsored enterprises that purchase mortgages from banks and mortgage companies in an effort to create liquidity so that lenders have the capacity to lend to more homebuyers).

The Office of the Comptroller of the Currency (OCC), The Board of Governors for the Federal Reserve System, and the Federal Deposit Insurance Corporation (FDIC) proposed a rule to amend the agencies regulations requiring appraisals for certain real estate related transactions. The proposed rule would increase the threshold level at, or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.

In response to our request for comment, spokespeople for the FDIC, the OCC, and The Federal Reserve said they do not comment on proposed rules during the rulemaking process.

Mortgage volume has trended lower despite rates falling steadily since the housing bubble, because lenders don’t want to take on risk, Miller said. “They’re in the fetal position. Banks are afraid of their own shadow.”

The tremendous amount of regulation implemented since Dodd Frank has led to mortgage lenders filling Fannie and Freddie’s portfolios with low-risk “pristine” mortgage bundles. But with rates so low, margins are so compressed, regulators need to stimulate volume to make money, according to Miller. “I think (Fannie and Freddie) are emboldened to take more risk.”

The push for fewer mandatory appraisals isn’t the only thing that has hurt the appraisal industry since the Dodd Frank Act was passed in 2010. The evolution of the mortgage industry’s use of the Appraisal Management Company (AMC) has led to a collapse in quality of appraisals ordered by banks, Miller said. He described the AMC as an institutional middle man that takes more than 50 cents on the dollar away from the professional appraisers who do the actual work.

“It’s like a Hollywood actor paying their agent 60% instead of 10%,” Miller said. “The mortgage industry is trying to widgetize the appraiser.”

The AMC is supposed to act as a communication barrier between the appraiser and the loan officer or mortgage broker, to thwart undue pressure to bring appraised values in at specific numbers. But according to Miller, the AMCs are under the same types of pressure that an individual appraiser might face. Some AMCs receive hundreds of thousands of dollars every month by way of appraisal orders placed by big banks. At least at the sales level, the banks apply pressure to the AMC to not “kill deals,” said Miller, who has testified in several class action lawsuits against AMCs.

In many instances, Miller and his firm were hired to do sample reviews of appraisals that came through AMCs. Often, the AMC would utilize appraisers in the market that would always “hit the number,” Miller said. A lot of those appraisers were ignoring valid comps, sometimes from directly across the street that were virtually the same as the subject property. “The AMC encouraged it because they were getting the work,” he said.

Appraisers are pushing back and there are already signs that AMCs were beginning to crumble, Miller said. Quality appraisers are turning away bank work when they know the order is coming in through an AMC because they’re not happy working for less than they deserve and because they’ve been reduced to “form-fillers,” Miller said.


The Apple Peeled Blog, February 12, 2019

Espinal Adler Team at Douglas Elliman Real Estate

Tags: , , ,


August 24, 2018

Who Wants To Own A House?

One of my sons told me about this “Who Wants To Be A Millionare?” winner.

I hardly watched this game show series because:

A) I’m not down with rhetorical game show titles. It reminds me of an old Mike Ferry technique I heard in Chicago – agents would say something like this when they walked into a home with their buyers: “Having a fireplace is important to you…isn’t it?
B) I wouldn’t like being asked general questions in public as seen as “Are You Smarter Than a 5th Grader?”
C) I hardly watch TV.

And thankfully I have never stumbled across rhetorically-title game shows while channel-surfing: How’s Your Mother-in-Law? – Who Wants to Marry a Multi-Millionaire? – Who Wants to Marry My Dad? – Who Wants to Be a Superhero? – Who Wants to Be Governor of California? – How Do You Like Your Eggs? – Do You Trust Your Wife?

I know all the answers already. Still, I’d like to get a call like this from one of my sons:


But I digress…

PBS NBR CNBC Videos – State of U.S. and Manhattan Luxury Market

CNBC’s Diana Olick reports on luxury home sales dropping in NYC due to tax laws and fewer international buyers.

CNBC clip

NYC luxury apartment sales drop from CNBC.

PBS Nightly Business Report clip


[Story with 2 clips begins at 18:20]

It is past the middle of August so it was odd to see that the Wall Street Journal ran a story that covered a new “half-year” report by a brokerage firm on the Manhattan luxury market from January 2018 to June 2018. But it was a good story nevertheless.

Almost two months had passed since that reporting period so CNBC reached out to me in response to talk about our already released first and second quarter Elliman Reports, as a segway to the luxury homebuilder Toll Brothers record earnings release.

More importantly, I didn’t wear a tie at the 30Rock studio interview. Hey, it’s summer.

Let’s Talk About Cutting Interest Rates, But First, Let’s Raise Them

What a time we’re living in. The Fed is talking about raising rates in September and possibly December, and even through next summer. But since they are anxious about the trade war we find ourselves in, rates could fall next year into 2020.

For the past year, the rate hikes always felt like there were designed to give enough room to cut if the economy runs out of gas by 2020 as many economists seem to be suggesting. There are signs that some sectors of the housing are weakening. This is clearly being seen in the housing market where existing home sales are at a 2 1/2 year low.

Affordability Gap In Long Island, NY Continues to Expand

Long Island is one of the few regions in the NYC metro area where both price and sales trends continue to rise. But the rate of growth is easing. Newsday wrote a good piece called Home prices are outrunning wage growth on Long Island.

My favorite points made in the piece were this:

Nassau residents earning the county’s average annual wage of $60,775 would need to spend 69 percent of their income to buy a home at the median price of $500,000 in the April-to-June quarter…

In Suffolk, residents would spend 56 percent of the county’s average yearly wage of $58,721 to buy a median-priced home for $372,500…

and

Nassau residents earn a median household income of $102,044, according to Census estimates for 2012 through 2016. That’s up nearly 42 percent from 2000. In Suffolk, household income grew by 25 percent, to $90,128.

In the same period, home values soared by 86 percent in Nassau and more than doubled — rising 103 percent — in Suffolk, census figures show.

They used the data from the Elliman Report series I author.


“X” Marks The Spot: U.S. House Size Versus U.S. Household Size

No rocket science here but I thought it was interesting to see how much these trends are moving in opposite directions.


[Random! But Not Really!]

“Cheery” Home of Mass Murderer for Sale

There was an article in Realtor.com about a home in Reno once owned by the Las Vegas mass shooter. I was surprised it was for sale since we often read about these homes being torn down when they are linked with horrific crimes. But it is a noble attempt to raise funds to benefit the famlies of the victims.

The home of the shooter in Newtown Connecticut was torn down as was the elementary school because the tragedy could not be erased. We run into this sort of thing on occasion but not nearly on the scale of these tragedies and as time passes, the discount declines until it is no longer apparent – At the other end of the spectrum, I once appraised a townhouse in Manhattan for a divorce where the husband blew himself and the house up. It became a land sale and there was no apparent discount.

A well-known real estate valuation specialist for these types of tragedies that was interviewed for the article also said:

What the article does not mention is that I think that those who buy these properties and get them back to quasi-normal use, help the community move forward and heal.

Appraiserville

Appraisal Institute Spent One Year Searching For 2X President Jim Amorin To Name Him CEO

As I predicted in these Housing Notes a while back, Jim Amorin is the new AI National CEO. It was inevitable that Jim Amorin would be named the replacement for former CEO Grubbe. Ironically Grubbe’s resignation was accepted by Amorin exactly one year ago today. Grubbe served a decade and I’m told created a toxic institutional culture. There was great hope by the membership that fresh faces in AI National leadership could right the ship from its declining membership, unending dishonest efforts to fight for issues that hurt the profession and their general irrelevance to consumers of appraisal services and regulators. The network of state coalitions are now in the regulatory conversation in D.C. and AI National is becoming a “stone in their shoe.”

It looks like the all of the membership’s money spent on a third-party firm to filter the applicants may have been a sham. The CEO position pays a whopping $400,000 salary so a 25% executive recruiter fee could be $100,000 cost. There were many applicants for the position and one of them had to be a hell of a lot more qualified than a status quo choice of the handful of senior execs that are the problem.

I got a lot of feedback from distraught MAIs when the news broke, who are resigning in the near future. Here some of my favorite quotes.

Fewer institutions are requiring the MAI of their staff, and more of them hewing to the FIRREA law on state certification as the qualification. It’s a natural progression that dues-soaked Appraisal Institute members, including prominent MAIs in the major markets, would look at the cost of the designation versus the return on that investment, and decide to leave it behind. This is especially true in light of the fact that members are realizing that their dues are going to support National and only National (2016’s chapter-money-grab), and that National’s interests are not those of the rank and file. How many MAIs and SRAs enjoy seeing their dues going to pay for very fat salaries of non-compete positions, and for the luxurious international jet-set lifestyle of the management and executive committees? The MAI has less and less value…unless you are in that 0.00001% at the top, getting a pre-departure glass of champers in the forward cabin.
It’s nothing short of breathtaking to watch a once-proud organization devolve into a parody of itself. I wonder how much money and time they spent on what obviously was a foregone conclusion months ago.
Looks like the “fix” was in…..and there is the only thing to say about this: Bad f##king decision! I just can’t believe this.
Just as you predicted. Self-interests have taken over all aspects of the Appraisal Institute.
Warm up the bugle. Taps will be needed soon at the AI funeral!
I will pay dues again in 2019, but I very likely will not for 2020…It pains me that my dues dollars will support these self-interested buffoons that have hijacked the organization. Never thought I could see the day where I would think like that – but it is here!

Here are some thoughts…

After the Nashville AI conference, it was incredibly obvious that the decision had already been made and they were trying to slide it in without incident. A story shared to me by two colleagues on different occasions who were told by someone who attended the Nashville Convention: When it was announced that Jim Amorin was to receive a special award for acting as the CEO for the past year, an appraiser stood up in the audience and implored leadership not to install Amorin as the new CEO because it would be the “death knell” of the organization. The audience applauded in agreement.

When the AI National sent the notice of the new CEO in their email blast, the story was buried in the second to last article.


Membership is being managed by a few elites at the top. Their echo-chamber is too loud for them to hear us any more.

Brian Coester, the controversial founder of a national AMC, has been served with criminal charges

Because Coester is a controversial figure in the appraisal management company industry and has been a frustrating topic of conversation by the residential appraisers for a while, it is worth pointing out what is in public record right now.

The District Court for Montgomery County served a summons to Brian Coester yesterday for “Interception of Communication.” This essentially means “email hacking” in statute CJ.10.402 under Maryland law. Translated: “Hacking the personal email account of appraiser Mark Skapinetz.”


“Spirited” Banks Treat Appraisers Like Cattle Where Clerical Staff Determines Their Livelihood

Warning: lots of “spirited” inside jokes abound.

No offense to the cows I’ve met in my lifetime (none are on a first name basis with me). When an institution has “spirit” it is all about the lowest bid and fastest turn time…period. Clerical staff usually makes the choice when institutions (with spirit) treat their appraisers whose spirit has been crushed, like this.

In looking at this particular request, here’s what I find — we uploaded the request around 11:30 yesterday. The “huddle” on Appraisal Shield pushes each request out to an appraiser about once an hour — I did a couple of extra pushes on this request because I had been delayed in getting out. As of this morning, this request had been pushed out to 14 appraisers — you were #12 in the rotation. We typically like to receive 3 – 5 bids before making a choice. When the assistant accepted a bid this morning at 9:19 a.m., we had received 9 bids and she chose the one that had the cost bid and delivery time that worked for this project.

My understanding is that the huddle is based on random rotation and I can see on other projects where you were notified much sooner in the process.
California Coalition Sends Critique of Sham Effort By AI National to Congressman

Why on earth would AI National do this? We will never know. This is why it is a bad idea for coalitions to co-sign ANY letters with AI National going forward. Please stop. After being kicked out of TAFAC and resigning from The Appraisal Foundation, AI National is doubling down on building relationships with the state coalitions who are now making real progress at the state and federal level. Why should coalitions align with AI National after they continue to insert duplication and misrepresent the state of our industry to regulators and politicians?

Remember this – Bill Garber’s common refrain continues to be “we are the most over-regulated profession” in every one of his presentations. Be advised that this is absolutely false and self-serving to AI National.

As a result of Bill Garber’s efforts, the California Coalition sent a note to the congressman who at AI National’s request, created the “Discussion Draft titled ‘To Establish a National Appraiser Licensing System and Registry for licensing and registration of real estate appraisers and appraisal management companies, and for other purposes.” [download]

Please read CCAP’s Letter to Congressman Stivers Discussion Draft. They point out how redundant this draft actually is and how it lumps Appraisers and AMC’s’ together, a clear reflection of AI National’s strong alliance with REVAA (the AMC trade group).

(OKPAC) disassociates from the comment letter submitted by the Appraisal Institute

While AI National got a bunch of cosigners for a letter critical of the North Dakota appraisal waiver request, they also falsely claimed that the ASC posted private information from North Dakota on their website which is patently untrue. AI National still hasn’t apologized or corrected the letter for this criticism likely designed to malign ASC as part of the longstanding strategy to malign The Appraisal Foundation in order to take their place in some capacity.

Here is how the OK Coalition responded to the misleading AI National claims about the North Dakota data:

Mr. Garber et al,

Within email below Mr. Jim Park clearly and unequivocally explains action in response (which entails federal rule of law) regarding North Dakota request for waiver. Therefore, based on the information provided, the Oklahoma Professional Appraisers Coalition (OKPAC) disassociates from the comment letter submitted by the Appraisal Institute with emphasis on the following paragraph:

“We are also concerned the North Dakota request published on the ASC website includes personally identifiable information such as names, email addresses, fees, and turnaround times. Such information was deemed to be privileged by the ASC during the consideration of the TriStar Bank temporary waiver request earlier this year. In fact, full and complete information on the TriStar Bank temporary waiver request was only obtained through a Freedom of Information Act request at the state level, as a copy of the request letter received by the ASC was sent to the state appraiser regulatory agency, per ASC regulations. This inconsistent and disparate treatment of appraiser personal information is alarming and should be immediately addressed in a consistent manner by the ASC and within the ASC regulations.”

In further clarification of disassociation here is the following action taken by ASC:

“The Submitter made the request, including all addenda, public by providing the request to appraisers in North Dakota and others themselves. As an added precaution, prior to posting the submission on the ASC website, ASC staff reached out to the submitter and asked if any of the information in the submission was confidential and should be redacted prior to being made public. Their answer was no.� In comparing this submission to TriStar submission and eventual waiver request, they did ask for certain information to be redacted prior to publication on the ASC website, which we did.”

OKPAC continues to support the denial for a temporary waiver of appraiser requirements in North Dakota.

Respectfully,

Thomas E Allen, SCRP, RAA
OKPAC

Other coalitions are going to be responding to this in the near future including ours. Just when you think AI National is changing their attitude, they pull this.

Brilliant Idea #1

If you need something rock solid in your life (particularly on Friday afternoons) and someone forwarded this to you, or you think you already subscribed, sign up here for these weekly Housing Notes. And be sure to share with a friend or colleague if you enjoy them because:

  • They’ll buy a house;
  • You’ll raise rates;
  • And I’ll mark the spot with an “X”.

Brilliant Idea #2

You’re obviously full of insights and ideas as a reader of Housing Notes. I appreciate every email I receive and it helps me craft the next week’s Housing Note.

See you next week.

Jonathan Miller, CRP, CRE
President/CEO
Miller Samuel Inc.
Real Estate Appraisers & Consultants
Matrix Blog @jonathanmiller

Reads, Listens and Visuals I Enjoyed

My New Content, Research and Mentions

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July 13, 2018

Housing on Fire

It’s always disconcerting when an office building behind yours catches on fire.


Then you remember when the building next door recently collapsed and tragically a construction worker died.

Then you recall the building across the street burning down and collapsing at your prior office (I took this photo from my office window).


And you think aloud, I STILL LOVE NEW YORK!

Also, a shoutout to my Columbia MRED Students! Remember that pie is better than cake no matter how convenient the housing analogy is.

But I digress…

Market Report Gauntlet Q2-2018 Week 2: NYC Metro Area

Just a quick reminder that any of our market reports that are published during the week are linked at the bottom of these Housing Notes in a section called “Recently Published Elliman Market Reports” so you’ll get them shortly after they are published.

I’ve been the author of an expanding market report series for Douglas Elliman Real Estate since 1994. We are in the middle of the quarterly gauntlet of 4 weeks and 30+ reports that are being published. The theme in the NYC metro area seems to be falling sales, rising inventory and flat to modest gains in price trends.

Firstly (literally), the number one read story on the Bloomberg Terminals yesterday by early morning and remaining there all day (350k± subscribers) was housing market story featuring the 2Q18 Elliman Report on Westchester.

and a chart…


and a chart…

within their coverage of the Elliman Report for Manhattan, Brooklyn & Queens June 2018 rentals that was published yesterday.


Refer to the links at the bottom of the page to see the other reports that I independently authored for Douglas Elliman published yesterday.

Charts for This Week’s Market Reports

We update a large library of charts on the regions we report on. Here was some of my favorites for this week’s report releases:

Bloomberg Markets Interview: July 10, 2018, Manhattan Housing Market

I enjoyed my sit down with Vonnie Quinn and Shery Ahn on Bloomberg Markets this week. The discussion focused on the release of the Elliman Report: Q2-2018 Manhattan Sales that I have authored since 1994 and the Bloomberg story that covered it.


We Are So Down On The 1909 Toilet, Literally

The Modern Bathroom of 1909. Except for the shower, it looks like half of the bathrooms I’ve seen during my appraisal inspections. I’ve also seen a lot of bathrooms in pre-WWII Manhattan co-op apartments that were made minimalist modern and didn’t translate much value to potential buyers. The trick to maximizing the value it seems is to have modern amenities with a pre-war aesthetic when in a pre-war building. Otherwise, it’s like joining someone for lunch at a steak joint and they only order a salad – its disorientating.

Sharing More Visualizations Done By Len Kiefer Because I Can’t Help It

I just can’t help myself. Len tweets:

I use this chart often, but it still surprises me. From 1968 to 2007 there were only two years when the U.S. completed fewer #housing units than it did 2017.


And we wonder why there is an affordability crisis in the U.S. housing market. Production has not recovered since the financial crisis.


Revisiting Angelo Mozilo and His Doomed Mortgage Machine

“Spray on tan” was never an option.

During the housing bubble, I remember thinking about how BofA had avoided the systemic insanity of lending that overtook most mortgage lenders including banks like Washington Mutual…and then they bought Countrywide and all hell broke loose. From the appraisal perspective, I observed them incorporate the Countrywide’s Landsafe Appraisal Management Company into the mix and all of a sudden, they took half of the appraisal fee and applied military-like rules such as 48-hour turn times and 19-year-olds chewing gum who followed long checklists without regard for local market knowledge. Quality appraisers fled. And then banks I loved working with like US Trust were gobbled up and they were forced to use Landsafe too. In 2015 Corelogic bought Countrywide as part of their acquisition binge. Bank of America and US Trust continues to use Corelogic’s AMC and have been reaching out to us intermittently for years to get our firm to work for them. However, CoreLogic, as a big machine, and near monopoly, can’t stop being a stereotypical AMC. That’s bad news for consumers and taxpayers.

Here is a good CNN/Money take on Angelo Mozilo and the damage he caused in the nation’s rush to enable more homeownership. His legacy of his Landsafe AMC still lives today within CoreLogic.

Appraiserville


This week is full to the brim…

When Untrained Inspectors of Hybrid Appraisals Rule The World

I did a screenshot of a photo from a private appraisal group that blew my mind. Now imagine an unregulated, non-standardized, untrained inspector (home inspectors aren’t being used for hybrids) for a hybrid appraisal assignment (being paid $12 to rush through a home) actually catching this scam like a trained experienced appraiser did. LIA (Liability Insurance Administrators) has said that the appraiser is still responsible for house conditions even if they use a disclaimer. I heard this directly from LIA when they presented at TAF a few months ago. I wonder what other things would be missed by an unregulated, untrained inspector that is in a new industry that is non-standardized?

Calling On All Tennessee Appraisers To Take a Tristar Bank Selfie

My wife and I were visiting good friends in Nashville and I thought it would be a good idea to visit the bank that misrepresented to the public that there were not enough appraisers in the area so they applied for an exemption to the Appraisal Subcommittee (ASC) for a one-year waiver. After all, they are local residents and as bank employees, can apply values to collateral they lend on and there is no conflict of interest to be concerned about (especially since the taxpayer will pick up the tab when all goes wrong). Right?

It would be cool to have appraisers submit their selfies in front of Tristar ATMs, branches, and offices to me and I’ll publish it here. I just submitted a request to the Tennesse Coalition through a friend but haven’t heard back yet.

I’m not confident the Tristar Bank saga and potential new requests from banks are over. Afterall, their twitter account is still locked. Why would a bank hide behind a locked Twitter account?


My Thoughts on the Tristar Bank “Appraiser Shortage” Misrepresentation and How Appraisers Fought Back

I was involved in the groundswell of opposition to the Tristar’s claim of a shortage and shared conversations and emails with appraisers in that area. My state coalition was among the many that wrote ASC to dispute the claims by Tristar that are easily refuted with a quick Google search. This is what I understand happened through conversations with my peers during this situation in late 2017 through spring 2018.

  • Appraisers physically went to their headquarters and branches to apply.
  • Appraisers called them to apply.
  • Appraisers inundated their twitter account to call them out as misrepresenting a shortage and offered to apply (Tristar locked their Twitter account – when does a bank do that? – still locked)
  • I was told stories of appraisers walking into branches, but don’t know what happened.

Statistically, it is easily proven that there are plenty of appraisers – as has been part of the public discourse. The onus should be on them, not appraisers, to be in sync with the public market to engage appraisers whether it is fee driven or a flawed bank culture. Why aren’t other Tennessee banks making such a claim now that Tristar’s claim was rejected? In appraiser parlance, other banks making the same claim would be a “comp” but that hasn’t happened. Why? Because they are misrepresenting the situation.

Here is a list of some of the past Housing Notes/Appraiservilles that will get you up to speed on the disingenuous claims by Tristar Bank:

AppraiserFest 2018! November 1, 2 and 3! San Antonio!

Signup now!

Besides the appraiser-orientated content, the team is working hard to expand their list growing list of states that will provide CE credit for attendees.


2018 RAC Fall Conference, September 13, 14, Plano Texas

I am the outgoing president of RAC (Relocation Appraisers & Consultants), an organization of the best appraisers of complex residential properties in the country, bar none. Its been an especially satisfying two-year run. I’m especially excited about this year’s conference after last year’s success! CE credit and curated relevant content provided for today’s residential appraisers.

To signup or learn more about the conference, go here:

2018 RAC Conference: Time Keeps on Slipping into the Future

An Example of why CoreLogic’s Monopolistic Behavior is Concerning

Dave Towne shared this FTC link on CoreLogic’s acquisition of DataQuick and their efforts to stymie competitors like RealtyTrac from licensing data. Corelogic just settled with the FTC. CoreLogic has quietly become a near-monopoly in the data business. This includes providing software for many MLS systems as well as acquiring Countrywide, the poster child for all that is wrong with the AMC concept.

Polluting The Data Pool

Here is a wonky conversation by people much smarter than me. I cobbled it together and it is quite interesting – I gave no credit to the writers in the email I was cc’d in but I can if you wish:

Comment

Extensive mortgage lending regulations would have to change to enable trainees to do more than what is currently allowed, and for lenders to accept that involvement.

From what has been published so far, the forms change won’t happen until 2+ years from now.

The below is the primary reason why the ‘hybrid’, ‘bifurcated’, ‘alternative’ type reports cannot be (presently) used for FIRST MORTGAGES when the GSE is buying the loan.

They can be for secondary loan products………..which is why they came into existence and are being pushed to appraisers by multiple entities

The problem is the lenders don’t want to pay appraisers appropriately for their license, E&O coverage, and professional service. Smart appraisers have not taken the bait.


Response

The issue, which we discovered through the forum, is that these reports are being one as “Restricted Use” on [proprietary] software of the AMCs, that,

Coverts the appraisal to XML, which can then be directly uploaded to Fannie Mae, or dropped onto a 1004 for, because the per-printed form verbiage does not convert to XML from either a Fannie Form, or the AMC’s forms.

That’s the “high tech” we are supposed to be embracing.

So, the IAEG does not apply to not regulated bank lenders, such as Quicken Loans for example.

Do a bi-f appraisal for a non-regulated lender, on an AMC proprietary software, and surprise, Fannie can buy that loan from them if the appraisal shows up on a 1004 through the magic of technology.

If appraisers are going to do Restricted Use reports for lending, then they should be in PDF, because downloading and selling the data is not a “use” of a restricted report.



Revisiting Angelo Mozilo and His Doomed Mortgage Machine

If you came to Housing Notes only to read Appraiserville, consider scrolling up to read the story under this headline: “Revisiting Angelo Mozilo and His Doomed Mortgage Machine”

Brilliant Idea #1

If you need something rock solid in your life (particularly on Friday afternoons) and someone forwarded this to you, or you think you already subscribed, sign up here for these weekly Housing Notes. And be sure to share with a friend or colleague if you enjoy them because:

  • They’ll close their checking account at Tristar Bank;
  • You’ll think your toilet is more modern than it is;
  • And I’ll keep writing market reports.

Brilliant Idea #2

You’re obviously full of insights and ideas as a reader of Housing Notes. I appreciate every email I receive and it helps me craft the next week’s Housing Note.

See you next week.

Jonathan Miller, CRP, CRE
President/CEO
Miller Samuel Inc.
Real Estate Appraisers & Consultants
Matrix Blog @jonathanmiller

Reads, Listens and Visuals I Enjoyed

My New Content, Research and Mentions

Recently Published Elliman Market Reports

Appraisal Related Reads

Extra Curricular Reads

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