Collateral Underwriter- Too Much Too Soon
|I would like to communicate some concerns and suggestions regarding the roll-out of the Collateral Underwriter (CU) scheduled for January 26, 2015. This is not an attack on Fannie Mae or the CU. In fact, these suggestions support the potential of the CU in improving the loan process and the end result of having quality mortgages.
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.
|There is a myth among appraisers and underwriters that when the CU uses holistic regression analysis methods, the outputs will be infallible. Fannie’s training material clearly states that the CU analysis will produce some “false positives and false negatives.” This means that the outputted indications of the CU will sometimes simply be wrong. Right or wrong, the appraiser can expect to get a call from the underwriter/reviewer asking them to explain why the CU is suggesting something different than he/she reported. In terms of line-item adjustments rates (coefficients), regression analysis is just a tool that provides evidence, not proof. This can be demonstrated by scrubbing the same data with a different method, omitting a couple of sales, or by omitting or adding variables. When these things are done the coefficient in question may change significantly. Also, it is not unusual for a 90 percent confidence interval for a coefficient for the gross living area to range from as much as $40 to $70. This wide range is further evidence that the coefficient is only statistical evidence, not statistical proof.When there is a 90 percent chance that a coefficient will be within a specific range, this means that there is a 10 percent chance that the output is incorrect. From an appraiser’s perspective receiving additional evidence for a line-item adjustment rate after the appraisal and report are completed is counterproductive. Consider a house painter who is told to paint a room a certain shade of brown. However, the mother-in-law would be visiting soon and if she didn’t like the color he would be required to repaint the room a new color for free. The painter would say, if your mother-in-law wants to provide input about the color it must be done prior to my work, or I will have to charge for my additional work. If a client has any information for the appraiser, such as additional evidence of a line-item adjustment rate, they should provide it prior to the appraisal being performed, not afterward. If the appraiser performs adequate due diligence then he/she will have to charge extra to consider the additional information. I understand that Fannie Mae may have no intention for the underwriters/reviewers to require the appraisers to comment or provide additional support, however, if the CU provides it, the appraiser will almost certainly be asked to comment on it.
Jury of Your Peers
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.
|Here are a few suggestions:
• Do not report the comparison of one appraiser’s line-item adjustment rate to that of their peers to the underwriters. This information may be useful to Fannie, but is of no practical value to the underwriters or appraisers.• Postpone the underwriter’s access to any of the CU analytical outputs concerning line-item adjustment rates until both underwriters and appraisers have time to educate themselves on what the implications of those outputs are, and how they should be handled. Quite frankly, the appraiser could not comment on the CU analytical outputs without knowing the scope of work and due diligence that the CU used. This does not involve facts such as transaction and property data.• Fannie Mae should work with appraisal and mortgage organizations to encourage more related training. It is a simple truth that no system can be successful without the users being properly trained. Consider promoting standard certificates of “Valuation Analyst” and “Underwriting Analyst” that establish competency levels necessary to successfully take advantage of the CU system.
• 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?
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.
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.