Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#2132363 - 05/30/17 05:40 PM Appraisal Dispute Reviews
Minion Offline
Member
Minion
Joined: Jun 2015
Posts: 64
Virginia
I am trying to find out what exactly the requirement is for a person who does the review for appraisal disputes. Currently the person handling them was a prior underwriter and was reviewing the appraisal as part of the underwriting process. If she/he agrees with the dispute then they forward it back to the AMC to have it redone or looked at. Does the prior underwriting experience qualify them to review an appraisal dispute that has been received? If not what exact qualifications should they have to handle a disputed appraisal?

Return to Top
#2132391 - 05/30/17 07:02 PM Re: Appraisal Dispute Reviews Minion
Tracey, CRCM Offline
Platinum Poster
Joined: Jul 2015
Posts: 542
Gorham, ME
In my past, anyone who was reviewing the disputed appraisal should be someone who has never seen any part of the loan before. So it could be another underwriter who knows nothing of the loan or property or a designated individual that only reviews appraisal disputes.
_________________________
Tracey

Return to Top
#2132396 - 05/30/17 07:18 PM Re: Appraisal Dispute Reviews Minion
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Who is disputing the appraisal?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2132397 - 05/30/17 07:31 PM Re: Appraisal Dispute Reviews Minion
Tracey, CRCM Offline
Platinum Poster
Joined: Jul 2015
Posts: 542
Gorham, ME
To clarify my response, the appraisals are disputed by the customer.
_________________________
Tracey

Return to Top
#2132401 - 05/30/17 07:52 PM Re: Appraisal Dispute Reviews Minion
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
That truly does not come into play unless the dispute involves factual information - like they got the square feet wrong. Other than that, once the independent appraisal is complete and reviewed and accepted by the bank - the story ends there. To allow otherwise jeopardizes the appraisal independence.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2132444 - 05/31/17 12:53 PM Re: Appraisal Dispute Reviews Minion
Minion Offline
Member
Minion
Joined: Jun 2015
Posts: 64
Virginia
So if the realtor or the borrower comes back and states they do not agree with the appraisal results the dispute is sent to a person outside of the mortgage area who has prior underwriting experience. That person then reviews the appraisal to see if they agree with the consumer that something does not seem right or if they feel the appraisal is fine. If they agree it is then sent back to the AMC for review.

The reason for my question is that the rule states that a reviewer should possess the education and expertise to review an appraisal. What I am trying to determine is what exactly is the education they are asking for here.

"An institution should establish qualification criteria for persons who are eligible to review appraisals and evaluations. Persons who review appraisals and evaluations should be independent of the transaction and have no direct or indirect interest, financial or otherwise, in the property or transaction, and be independent of and insulated from any influence by loan production staff. Reviewers also should possess the requisite education, expertise, and competence to perform the review commensurate with the complexity of the transaction, type of real property, and market."

Return to Top
#2132455 - 05/31/17 01:35 PM Re: Appraisal Dispute Reviews Minion
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
I have reviewed appraisals in a previous life; however my job was not to determine if the value was sufficient. My job was to determine if the appraisal met the guidelines, if comps appeared reasonable, if adjustments were accurate, etc. If it met the regulatory and bank requirements the appraisal was 'good'. Often borrowers believed their property was more valuable.
_________________________
My Opinions Only

Return to Top
#2132468 - 05/31/17 02:49 PM Re: Appraisal Dispute Reviews Minion
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
As for education: Same as Skittles...in a former life, I reviewed the appraisal reports, too. My job was not to agree or disagree with the value but to make sure that the appraiser got there correctly. Did the appraiser inspect the place, what data did he collect and use, was there enough data used, how were adjustments made and why, were all of the calculations done correctly?

I stayed current on banking guidelines and USPAP. There was some continuing ed that was offered (I'm thinking it was from appraisers?) on reviewing sales and income approach that was very helpful, especially for the larger, more complex commercial appraisals.

As for disputes: Once I said yes to the report and forwarded it to lending - - -that was it. The only times I remember getting any push back were those similar to Randy's square footage above. Once, I matched the property to the engagement letter and the appraiser matched to the county records - - turns out both of us were supposed to magically know that the borrower was offering the bare lot adjacent to the home as well.

If the appraisal was done correctly and the borrower doesn't agree with the results, they should be able to point to something specific, yes? My lot is bigger; he missed a bathroom; that's a 3-car garage, etc. Then that is something that can be taken back to the appraiser for review and possible revision.

Hope that helps some. I can look for where I got that training. It will be dated, but might be a start.

Return to Top
#2132767 - 06/01/17 07:40 PM Re: Appraisal Dispute Reviews Minion
Minion Offline
Member
Minion
Joined: Jun 2015
Posts: 64
Virginia
Knowing what training you had would be great. I am just afraid if we were to get audited and they looked at the person doing the disputes they would want to know what prior experience they had to know that a comp appeared reasonable or if the adjustments are accurate.

Return to Top
#2132787 - 06/01/17 08:59 PM Re: Appraisal Dispute Reviews Minion
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I will say it one more time. If the appraisal has been completed by a licensed or certified appraiser and it has already gone through your required normal appraisal review process and has been accepted by the bank, the only dispute available is a factual dispute, such as the property information is not correct. In that case, the appraisal would be returned to the appraiser for correction. A disagreement regarding comps or adjustments would involve an interested party to the transaction influencing the value, which is not allowed. It sounds like to me that you are creating a process for something that should not be happening.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Lestie G