Collateral Underwriter- Too Much Too Soon
by David Braun, MAI, SRA

Let me introduce myself so you can understand my perspective. I have been a working appraiser for 39 years. I have been studying statistics for over eight years, specializing in regression analysis. I have no degrees or formal education in statistics. I call myself and people like me “valuation analysts,” as I have one foot squarely placed in traditional valuation methods and the other in the statistical world. I have no axe to grind with Fannie Mae; I like many of the things it has done and dislike others. As an appraiser, I am highly attuned to its influence on how appraisers perform their work. I performed residential appraisals for the first 20 years of my career, and commercial appraisals the remainder of the time. In addition, I develop seminars and regression software for appraisers.

I have been using regression analysis in conjunction with appraisals and have run literally millions of scenarios of regression analysis in a laboratory setting to understand what it can and can’t do for appraisers. When the 1004MC form was introduced, Fannie submitted an email to appraisers dictating how to count the listings for the month’s housing supply (MHS) calculation. I published an article on the web indicating that the calculation method would often over-state the MHS by as much as 50 percent. I am not sure the folks at Fannie ever saw my article, but they did later retract the stipulated method, replacing it with a better one. The point being that as the old saying goes, two heads are better than one.

CU Upside
There are many potential upsides to the CU. Perhaps the most applauded by appraisers is that the CU is actively trying to identify the handful of unethical appraisers. Ethical appraisers would like to see the CU swat them like flies. I have personally seen appraisals where the comparable’s data were fiction. Unfortunately, many of the appraisers who tend to inflate values are sometimes encouraged by a few underwriters. The CU is going to make this unethical group of underwriters uncomfortable, as there is now a check and balance system in place. You can see I support the use of the CU for a lot of reasons. Let’s move on to some of the negative aspects, and what might be done to prevent them.

CU Downside
I have worked closely with underwriters over the years, and they do not pretend to be appraisers. They work with a simple checklist for review. I have personally been contacted from call centers in India who were the ones filling out the checklists. When the appraiser legitimately varies from secondary market guidelines there is a real problem explaining this to the holder of the checklist because they just don’t understand the guidelines well enough. Now imagine these same underwriters and reviewers looking at the CU program on their monitor. I don’t see how the CU is going to enable them to address the legitimate exceptions to the statistical analyses provided to them by the CU. The result will be an unacceptable addition of time and effort on the appraiser’s part to explain the issues. Some appraisers may simply throw up their hands, and modify their appraisals to meet the suggestions of the CU. This path of least resistance is the last thing that should happen, not to mention it will tend to erode the appraiser’s independence.

Jury of Your Peers
Many of the outputs of regression analysis are more reliable than the line-item adjustment rates. For example: identifying variables which have a relationship with value, identifying the random variance associated with a market, and final value estimates. These sorts of conclusions may be useful to underwriters.

The check that the CU will perform by comparing what the appraiser did to his peer group is problematic. This will penalize the very good appraisers who will be asked to explain why their conclusions are different from less experienced, inferiorly trained, or unethical appraisers. Considering a bell curve perspective, it is likely that you could divide appraisers into three groups, below average, average, and above average. This means that the majority of appraisers would be average or below. The implication is that the good appraisers should conform to the actions of the less credible appraisers. A reasonable answer from the good appraiser to the underwriter might be, “Yes, because I am a better appraiser than the overall pool of appraisers, I would expect my conclusions to often be inconsistent with the other appraisers.” Again, I am not saying it is Fannie’s intent that the underwriters will require an explanation from the appraiser, I am saying it will, none the less, be the reality appraisers are forced to deal with.

• Data that includes quantifiable rating systems for condition and quality of the improvements tremendously adds to the effectiveness of statistical analysis. This superior data, which was gathered and assembled by appraisers, must be accessible to appraisers. Appraisers have access to regression software, but not the superior data Fannie has collected from their appraisals. If one of the goals is to improve the quality of appraisals then it is not logical to withhold high quality data from the appraiser.

• Fannie and appraisers must accept that compliance with the Uniform Standards of Professional Appraisal Practice (USPAP) is the best avenue to a credible appraisal and report. Fannie Mae would best be served by working with the State Appraisal Commissions and Boards to include additional USPAP compliance checks in the CU such as:

o Was the analysis of the highest and best use performed and reported?
o If applicable, was the land value analysis performed and reported?
o Was an applicable explanation reported for the omission of any of the major approaches to value?

I understand that USPAP compliance is the responsibility of the appraiser and the lender, not Fannie Mae. However, so is the reasonableness of the line-item adjustment rates, and the CU is providing analysis of them. Advanced holistic analyses are not necessary to predict the quality of an appraiser’s work who can’t or won’t meet the minimum requirements of USPAP. Any of the state agencies can list the prevalent USPAP violations that should be addressed.

Conclusion
The appraisal profession lacks a research and development arm which would develop things like the 1004MC form, better databases, and improved analysis techniques. I applaud Fannie Mae for moving forward to improve its business model. However, I believe the current plan to unroll the CU needs to be modified to reduce the potential negative aspects. The planned role out, could end up making Fannie Mae look like Don Quixote, and the underwriters and appraisers resembling Sancho Panza, if underwriters believe that the appraiser’s opinions should be similar to the outputs of the CU. If this happens, underwriters and appraisers will be fighting a lot of windmills. The truth is that the outputs of the CU are not statistical proof, they are only statistical evidence.

To minimize the chance of things going very wrong, the individual aspects of the CU should be phased in over a 12 to 18 month period allowing for more training regarding the implications of the CU’s outputs and how underwriters should best use these tools. Certainly, inconsistencies, inaccuracies, and data anomalies are examples of issues the CU should be flagging for underwriters. I am happy to answer any questions that Fannie Mae might have about my comments and suggestions.

About the Author
David Braun, MAI, SRA can be reached at david@AVTtools.com.www.AVTtools.com