You’d think client/user expectation would follow wise professional leadership. Hah!
Innovation and leadership in knowledge and education has declined. The profession and its key organizations have long lost their default position. Pride in designations are diminished. Replaced by licensing, outdated appraisal processes, echoed education, and octopus-like regulation. These are built upon subjective, belief-based ‘credibility’ standards. Each of these re-reinforce what clients want and expect. Why?
Lender-client employees focus on appraisal review, management, and loan production. Reviewers and Collateral Risk Managers are mostly appraisers. Loan production and underwriting practices are built on ‘established’ appraisal standards and regulatory requirements. Client/user policy is a repeat of what appraisers have learned, have licensed, have standardized, and have complied with. The doing/done/required process is circular. The five frictions of valuation, process, standards, education, client expectation, and regulation, reinforce stale procedures and policies.
USPAP (Uniform Standards of Professional Appraisal Practice) is edited every two or three years. New updates may simply undo prior updates. Chugga chugga.
USPAP mandates the use of “recognized methods and techniques.” The repeated required benchmark is ‘credible’ — defined as “worthy of belief.” The entire document focuses on credibility, the worthiness of the appraiser, not the reliability nor reproducibility of the result.
Appraisers are required to repeat the same education and repurchase the USPAP book every two years, even when changes take place over a three-year period. And pay fees for the privilege. “Automated valuations,” “evaluations,” and “waivered” ways do not have such taxes and ‘regulatory guidance.’ This creates a market advantage for the lesser-quality product!
Most importantly, USPAP sets the hard requirement for acceptable appraisal work scope: when it meets or exceeds “Expectations of parties who are regularly intended users for similar assignments.” And: “What an appraiser’s peers’ actions would be in performing the same or a similar assignment.” Users expectations and peers’ actions. Again, non-appraiser appraisals are not subject to such scrutiny.
Appraiser peers do what they are taught and what their peer-trainer-bosses were taught. The peer-trainer-bosses form the cadre of teachers of USPAP and the “recognized methods and techniques.” Then they take jobs with lenders and state regulatory administrative agencies. Round and round. (I have been one of these. My teaching conformed to what was directed, in turn-the-page instruction. In point-by-point class workbooks.)
Collateral lenders, particularly the GSEs Fannie Mae and Freddie Mac, (now under the effective public direction of the Federal Housing Finance Agency) then set ‘guidelines’ which echo and add to the subjective standards of worthiness. Thus the resulting client expectations comprise regulations, habit, conforming education, and peer’s peers. They continue to do what peers do – only the recognized methods and techniques. Any superior (but unrecognized) methods and techniques are discouraged. New methods may cause clients to complain. Avoid, avoid, avoid. No newfangled stuff!
Client/user expectations are embedded in the past. Why rock the boat?
Can we create a better, self-righting boat? Can we generate a new system of progressing regulations? A new system founded on today’s technology, not 1930s paper and pencil data gathering.
JOHN "JACK" FIENE
January 14, 2022 @ 10:33 am
Thanks, George. I was involved with the setting of appraisal standards and licensing during the 1980s, and sat on the Board of Trustees of the Appraisal Foundation during the 1990s. As Chair of the Publications Committee, I became extremely frustrated with wordsmithing by the ASB. Worse, all of the guidance material is now incorporated into USPAP; it is NOT USPAP, and FAQs are weaponized by attorneys. Sometimes depositions rage on for days over USPAP minutia.
– John F. “Jack” Fiene, MAI, SRA, SRPA
Scott D
January 14, 2022 @ 4:31 pm
All very true. I lacked all but one requirement to obtain my designation, and abandoned it several years ago when the AI required all members to be on track to be designated, which only dilutes the value of what before was an “elite” badge.
State boards have cookie cutter rules that make no sense (I am typically taking the USPAP education class 2 months before it expires (though I have been complying with it already for 22 months (hopefully)).
The quality of the education is low, and the quantity is high. Very few of us need 28 hours of remedial work. 4-8 hours of high quality learning? That would be very helpful. With the designation paths, I didn’t mind taking weeklong classes in specialty fields, but designations are now diluted.
What we will see is a continuing shift towards unregulated products — namely evaluations, as appraisals become more and more outdated. Appraisals will still have a place for refinances, estates etc. but I see residential lending based on the borrower’s credit, not the house’s value, and commercial lending will be heavily underwritten by evaluations.
Steve Owen
January 16, 2022 @ 5:15 am
Part of the problem is a wide variety of appraisal, but a rather narrow (even though octopus-like) set of standards. Big data available in some places and non-disclosure in others. People in the general public see Jay Leno’s old vehicle appraiser and believe that he just “knows” what the cars are worth. The job is very different for a residence in a subdivision than it is for a half finished retirement complex in a rural area. Not the same for a motel whose site value exceeds (or soon will exceed) the value of income from operation as it is for an old downtown building that has had government money put into the remodel. Education can help, but many appraisers in small market areas find themselves learning anew with each new assignment. The biggest part of the problem, IMHO, is that regulation of any profession is usually designed to limit competition as much as it is to protect the public. As long as lending is underpinned by the corrupt influence of government protection the problems you have outlined will persist. But, in the long run, there will always be some demand for appraisers who are credible and will not simply find the desired value. Credibility is, and always will be, the standard by which all professions are judged in the more honest parts of the world.
William Bert craytor
January 17, 2022 @ 12:06 pm
I agree. I currently use R scripts that call MARS “earth” for residential appraisals. It is a complex multi-step process. Now I have been also using Minitab/Salford Systems MARS since about 2004/5 with no complaints really. This year they increased the annual license fee to $16K/yr, and so I had to switch to R/earth. And in fact, I am better off, as I can use R script to automate the handling of data and spreadsheets. I even use 2-degree processing in R/earth. 2-way provides find and generates additional fields for significant two way interactions between variables such as GLA-Lotsize, GLA-Baths, Latitude-Longitude and so on, which then have to be merged into the URAR fields via Excel spreadsheets which Alamode that can thankfully import into the URAR forms.
With my methods, I can handle a dozen comps and have them adjust to precisely the same value (although loading into Alamode causes rounding to the nearest dollar).
Now, so far, AMCs and lenders haven’t complained about my methods, except to request the detail calculations behind the merging into the URAR forms, which I have no problem providing. Large AMCs such as UW-Direct, USRES, KAIROS, HVCC, and a few others accept the 80-110 page URARs via Alamode. I also use Chief Architect CAD for floor plans and drone photos. One of my complex reports hit the desk of a chief appraisers at one of the GSEs – who at least told me, – and they were guessing they were from me because of my posts on appraisersforum.com – that they could understand them, at least via the statistics experts they had access to. But since they were bound by some degree of confidentiality they couldn’t say much more. So, said appraiser wouldn’t say one way or the other whether he approved the report, because of course it most likely wasn’t allowed by the GSE and/or any agreements with the bank who sent him the report for review.
But I do get complaints from appraisers on forums, who really are not prepared to deal with non-parametric statistics, MARS, building R scripts and managing the construction of gigantic worksheets. That is a long-term worry.
So, I am worried that the educational system isn’t teaching the appraisers in the few real estate appraisal programs that exist more mathematics, non-parametric statistics, data mining and computer science in general. I always have to be worried that eventually there may be some push back. Which is understandable, as some banks probably do not have access to people versed in advanced statistics. So, I think maybe one bank via USRES did stop providing orders for that reason. But I am not sure. I still get far more bid request from USRES and other AMCs and lenders than I can possibly handle.
So, its something to worry about. But the real problem is that the right statistics is not being taught to appraisers, nor enough R and other coding skills.