William Fall: The Biggest Challenge With Collateral Underwriter 'Is The Scores'
by Orb Staff
PERSON OF THE WEEK: William Fall is the founder and CEO of Valuation Partners, a national appraisal management company with access to thousands of independent fee appraisers in all 50 states and many U.S. territories. MortgageOrb recently interviewed Fall to get his views on whether there really is an "appraiser shortage," as some claim, as well as how new regulations and new technologies are reshaping the residential valuations space.
Q: You believe the mortgage industry is facing a shortage of appraisers. Why? What impact will this have on the industry?
Fall: I do believe the industry is facing an appraiser shortage. Recent data from the Appraisal Institute confirms that the majority of today's appraisers are over 55 years old, and already appraiser shortages are affecting turn times in some markets, such as Colorado and Oregon. At the same time, I don't see many new candidates entering the profession.
The immediate impact of an appraiser shortage, of course, is longer turn times, which nobody wants. But there's more at stake besides delays. If the industry is unable to sustain a healthy balance of appraisers, we could see non-appraiser valuation models slowly replacing human expertise, which places the entire housing industry at risk for another disaster.
Q: Are the current qualifications to become a licensed appraiser a factor?
Fall: In my opinion, yes. To become licensed, the Appraisal Qualifications Board, an independent body of the Appraisal Foundation, currently requires new candidates to complete 2,000 hours of training under the supervision of a certified appraiser. Yet most appraisers work independently, and experienced appraisers are not typically motivated to help someone who may eventually become a competitor. That's a pretty big roadblock. Even appraisers who want to train others find it hard to do because new lending regulations are negatively impacting their workload. They just don't have time.
My belief is that there should be more than one way to become a licensed appraiser. The industry would benefit enormously by creating an alternative path to the profession that is based on one's competency, not just how many hours are spent in a classroom or out in the field.
Q: In which segments of the market are you seeing the greatest demand for appraisal services?
Fall: Independent mortgage bankers are the fastest-growing segment of the market, and that's where we're seeing a lot of new business. These companies are extremely consumer-focused, and they need an appraisal partner they can truly count on to deliver high-quality valuations on time and that has access to appraisers nationwide.
Thanks to new rules regarding third-party vendors, mortgage bankers also need confidence that their appraisal partners will keep them informed and can assure them of a compliant valuation process. To help, we've engineered a unique purchase appraisal process that consistently delivers high-quality purchase loan appraisals on time. Our process is designed to avoid delays through strict communication protocols that are built into every step, and it ensures that every report receives an accelerated quality review.
Q: What are you experiencing on the compliance side of valuation?
Fall: We face a number of compliance challenges, ranging from appraiser independence rules under Dodd-Frank and ensuring that all appraisers meet all licensing requirements.
To help lenders with appraiser independence, we've created guidelines and firewalls that make sure that all relevant information involving the appraisal is exchanged between all parties, and we never get involved with how appraisers arrive at their conclusions of value. To give lenders that extra level of assurance, we also provide a Certificate of Appraiser Independence (AIR) with all of our appraisal reports. Essentially, the AIR certifies that the report was created objectively and that none of the information in it has been misrepresented in any way. We also validate every appraiser's requirements before and after every assignment. This includes checking the appraiser's licensing status and errors and omissions insurance coverage.
Q: How is the Consumer Financial Protection Bureau's new TILA-RESPA Integrated Disclosures (TRID) rule affecting the appraisal process?
Fall: Although we're not directly affected by TRID, timelines are a huge part of the new disclosure rule, and the appraisal is perhaps the most time-consuming aspect of the mortgage process. On one hand, appraisers are facing pressure to turn around appraisal reports as quickly as possible. On the other, many lenders are interpreting other regulations and guidelines involving the appraisal process very strictly. More and more often, appraisers are being asked to review their conclusions of value or re-inspect the subject property for repairs. This creates a double-edged sword that is heightened when TRID's timelines come into play.
Q: What has been your experience with the new Fannie Mae appraisal scoring tool?
Fall: The biggest challenge with Fannie Mae's Collateral Underwriter (CU) is the scores. Every appraisal is summarized in a risk score based on a number of important factors, including data integrity and sales comparables. Appraisals with the lowest risk are given a score of 1, while those with higher risk are scored 4 or 5. The problem with getting a high score is that Fannie Mae isn't sharing the data that is being used to determine appraisal quality, so neither the appraiser nor the lender can know for certain why a report received a high score.
To help everyone get to the bottom of things, we created a tool to examine the possible reasons why an appraisal received a high CU score. Our Market$ense report goes over CU's findings in detail, and if the score can be improved, Market$ense provides the steps to get there. Every Market$ense report includes a point-by-point analysis by a certified appraiser, and the reports are free for every appraisal that receives a score of "4" or "5."
Since CU was launched last year, there has been a lot of concern from appraisers about how much extra work it would create. But there have been benefits, too. There has been no across-the-board improvement, but we believe CU has pushed the appraisal industry toward creating a higher-quality product, and that's not such a bad thing.