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HI there!

Appraisal modernization - We have tried to use desktop/drive by appraisal reports in the past. Calling them something different will not improve the valuation nor will it make the reports more accurate. Gutting the appraisal process will not make the reports more credible. In fact it makes a valuation less credible, as the one responsible for the value has no input on the actual inspection (which is the most important part of collecting and verifying facts about the collateral) The unintended consequences are great and will have a negative effect on tax payers and consumers alike. The standard for collateral will go down. The risk is not just assumed by the Fannie or Freddie. We saw how impactful their bad decisions have been in the past. They are powered by greed and stock holders. Not by an actual conscious. Gutting the appraisal process just allows the lending institutions to make their own decisions based on their perceived ideas of risk, not value. Further the banks sell the loans- why should they care what the consumer purchases? They do not physically own the collateral anymore. All of the risk is then put on the consumer at that point. Banks are on the lending business for one reason only (to make money). The question has to be asked - as to why is everyone in such a hurry to be in debt?

UAD-- I do not get to see it, but I am sometimes asked to review bad suggested sales by UAD. Most of the time they are not geographically correct or based in neighborhoods that are not comparable to the subject property. Suggested sales are often inflated nor usable for credible data. Comments I hear from bank employees /appraisal reviewers - UAD is not accurate in my area (Raleigh NC). Does not do a good job of filtering data. Only casts a broad net.

AVMS- waivers - are ok for easy transactions -rate term refi when the bank still has old documentation of the original transaction. Not on new loans. The problem is real estate is always changing and we will never get the data right from a Macro perspective. People screw their homes up all the time (which we discover via an actual inspection) Do banks really want to lend on bad collateral? Then they should be asked to hold the loan. Can an AVM spot deferred maintenance? Can an AVM smell cat urine? Do AVM's take into account functional obsolescence? The answer is no.

Valuation differences between ethnic groups.. I am a 38 year old white guy - I cant comment on what other people think. I do know I do my best on every report to be impartial and unbiased. I do not feel like this is ever an issue for me as I do not see color in people.

I started in the appraisal business at 16 as an office assistant. Did my training in college - became certified in 2007. This business is all I know. The answer is not gutting the process. The answer is higher educational standards and getting bad apples out of the field. Alternate education for new appraisers is a better answer than getting rid of them all together. We should be inviting college graduates with 4 year business degrees in to this field. We can't go backwards as an industry - as it has taken so long to rebound from the last rounds of poor/greedy decisions. I can elaborate on poor/predatory lending policies. I was a college student who was given an interest only loan for a house in 2006 - I was on a government Pell Grant for college as I was poor growing up - this loan should have never happened. This is going down the same road, but using a different vehicle.

WE ARE ALSO IN THE MIDDLE OF A PUBLIC HEALTH CRISIS. OUR COUNTRY AND ECENOMY IS FRAGILE ENOUGH. WHY IN THE WORLD WOULD ANYONE WANT TO MAKE LARGE BANKING TRANSACTIONS MORE RISKY FOR A CONSUMER? WHAT KIND OF NON-SENSE IS THIS??