Mary Cummins, Real Estate Appraiser, Animal Advocates, Los Angeles, California

Mary Cummins, Real Estate Appraiser, Animal Advocates, Los Angeles, California
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Showing posts with label great recession. Show all posts
Showing posts with label great recession. Show all posts

Tuesday, October 29, 2024

FHFA Allows Alternative Valuations with Higher LTV Ratios by Mary Cummins Real Estate Appraiser Los Angeles California

mary cummins, real estate appraiser, los angeles, california, real estate appraisal, fhfa, ltv, avm, appraisal, real estate,low income, poc, great recession, foreclosure
mary cummins, real estate appraiser, los angeles, california, real estate appraisal, fhfa, ltv, avm, appraisal, real estate,low income, poc, great recession, foreclosure

The Federal Housing Finance Agency FHFA has expanded the eligibility for alternative appraisal methods on purchase loans by increasing the allowable maximum loan-to-value (LTV) requirements. The maximum LTV ratios will increase from 80% to 90% for appraisal waivers and from 80% to 97% for inspection-based appraisal waivers. 

“To be clear, the expanded eligibility of appraisal waivers does not constitute an expansion of a credit box, but rather it will allow more first-time home buyers, and particularly low- and moderate-income first-time homebuyers, to recognize the benefits associated with appraisal waivers,” Naa Awaa Tagoe, deputy director of the division of housing mission and goals at the FHFA, said on stage."

More purchase loans will not utilize a regular inspection appraisal by a licensed real estate appraiser. They will be using non-licensed non-appraiser property inspectors and AVMs Automated Valuation Methods similar to Zillow. This means lenders can use their AVMs, in house approval departments to get higher values so they can approve more loans so they can make more money. These loans will be riskier to new buyers, investors and the government. The housing industry players have been directly lobbying the government to do this for years now under the guise of helping lower income "save money" and fighting nonexistent "appraiser bias."

Never forget the Great Recession. Real estate prices were booming and fewer lower to mid-income, first time buyers could afford to buy a home. The people complained it was discrimination against lower income and POC. There is a correlation between lower income and POC. The correlation is based on socioeconomic factors and not race. There are also plenty of lower income non POC. 

The government stepped in to "help" by lowering credit and loan requirements. More lower income first time buyers were then able to buy a home at the peak of the market for almost no money down. They had very little to no savings and were spending most of their income on home expenses. They were set up for failure by the government while lenders made lots of money. Lenders support relaxing requirements so more will qualify so they can make more money. Lenders lobby the government to reduce requirements while saying they just want to help poor people. This actually helps wealthy people at the expense of poor people just like payday loans. 

The real estate bubble of course burst and those people ended up underwater. Low teaser rate loans adjusted, some had financial emergencies and they couldn't pay their sky high mortgage, insurance, property taxes and property maintenance. It was cheaper to rent than own. The real estate market collapsed and people lost their homes in foreclosure. They lost more than just the cost of the home due to associated costs and fees. The psychological effect on the families was devastating. Oddly enough the people and government blamed appraisers even though it was the fault of the government and the bubble bust real estate market driven by buyer demand. Appraisers just report the market. We don't set it.

Today we're in a similar though slightly different situation. We're in another real estate upswing caused by previous lower interest rates and severely restricted supply due to rate lock. Everyone wants to buy a home that will appreciate 50% like they have in the last few years. They are again complaining to the government that it's discrimination against lower income and POC because they can't afford to buy a home today.

People are blaming the government for the wealth gap which they say is mainly caused by the home ownership gap. The wealth gap is mainly caused by the income gap. Owning a home alone is not the cause of the wealth gap. You need to be able to first afford to buy and own a home by having higher income, more savings and good credit. Higher income, savings, good credit must come first otherwise you just saddle yourself with debt and higher monthly costs you can't afford. You'll lose your home if you have one financial emergency.

Government did the same thing with student loans. "If you get a college degree, you'll make more money. Here are loans so you can afford to go to college." You'll also end up with $100,000 high interest debt which make it impossible to pay bills, have children, start a business or save to own a home. The correlation between having a degree and higher income is related to first being able to afford to pay for and go to college. It's not the degree itself as many people have realized. Same with owning a home.

The government again responds by lowering loan requirements. Now you can put almost nothing down and get stuck with hefty mortgage payments, rising insurance costs, high property maintenance costs and rising property taxes at the top of the market. Property taxes, insurance increase as property value increases. Insurance costs are through the roof today due to natural disasters exacerbated by climate change. The appraisal waivers and use of value acceptance, AVMs make the loans even riskier for buyers and investors. It's even riskier today as we are at the peak of the market. Two to five years ago and it would have made a little sense. The government always reduces regulations at the peak of the market because of lack of affordability and politics.

AVMs will over value lower priced properties which are generally in inferior condition, inferior locations, smaller than average, have deferred maintenance, include buyer concessions for repairs/costs... These are the properties lower income people are buying because they can afford them because they cost less. The government is again setting these people up for failure. They always do this at the peak of the market. 

I was screaming from the rooftops about this issue before the Great Recession. I'm now screaming from the mountain tops. Nothing will change. The government is hurting the people they claim they want to help.The election year campaign promises to get votes is making it worse. You know they will again blame real estate appraisers for a downswing even though we didn't appraise the properties that are most likely to be foreclosed. It's déjà vu all over again. 

https://www.fhfa.gov/news/news-release/fhfa-announces-updates-to-enterprise-policies-on-appraisals-loan-repurchase-alternatives-and-pricing-notifications

November 1 Jeremy Bagott just wrote a good piece on this.

https://mailchi.mp/257006d81c5f/days-from-election-agencies-make-good-on-final-sop-to-housing-lobby-10896727


https://www.housingwire.com/articles/fhfa-to-allow-alternative-appraisal-methods-on-purchases-up-to-97-ltv/

Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

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Monday, April 10, 2023

HUD only cares about appraisals UNDER contract price which is dangerous by Mary Cummins

appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value
appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value

Dave Towne sent out this linked article about bias and appraisal gap.

"The article below was in the Inside Mortgage Finance Publications e-newsletter on 4/06/23:

"FHFA Data Fueling Looks into Appraisal Bias

dhollier@imfpubs.com

The Federal Housing Finance Agency is a is a critical provider of the data necessary for oversight, enforcement and research, FHFA Director Sandra Thompson noted during a discussion in late March.

According to aggregate statistics from the Uniform Appraisal Dataset released by the FHFA, roughly 57% of appraisals were above the contract price in 2021. Just 15.2% were below the eventual sale price, but these are the under-valuations that could possibly reflect bias.

And the important datum here is that this percentage is growing. In 2013, only 8.4% of appraisals came in under the contract price.

In addition to providing data, Thompson noted that FHFA has coordinated with the Department of Housing and Urban Development, the Consumer Financial Protection Bureau and the Department of Justice “to provide additional information for fair lending enforcement and oversight.”

If this actually reflects the true thinking of Ms. Thompson, she has aligned with so many others who believe SALE PRICE is immutable, and is the ultimate indicator of Value, and apparently, of bias, when not accepted as gospel by the appraiser.  My gosh, what a misguided opinion!

Apparently Ms. Thompson didn’t see, experience or understand what happened during the ‘pandemic era’ in mid-2020-early ‘22, when overly emotional, and irrationally exuberant buyers paid astronomical prices for homes way above what their actual value was.  The same thing happened in 2006-2008.....but it wasn’t considered ‘bias’ then due to the different political climate and attitude at that time.

Conversely, how can it be said that valuing a property lower than its eventual sale price based on current market evidence is tantamount to BIAS?  And, if 57% of the appraised values were ABOVE the sales price, couldn’t that also reflect BIAS?  Seems to me that if one comparison in one direction is considered bias, the other in the opposite direction can be equally judged the same.

To better understand this concept, look up the definition of bias.

The political drumbeat of appraisal bias just because an appraisal Value doesn’t reflect Sales Price is blatantly wrong-headed.  In fact, it reflects internal personal bias at worst, and exhibits a definite lack of understanding of the appraisal process, by the person promoting such falsehoods.

More appraisers should stand up and challenge Ms. Thompson’s assertions."

I agree that we should be looking at the over valuations. That is probably where most of any alleged "bias" would be. In the major media cases of alleged bias the first lower appraisal is considered the wrong one when it was actually the higher second appraisal that was wrong and above market value. 

The second higher appraisals were influenced, biased by the AMC, Lender and borrowers who stated the first appraisal was too low. The second appraiser knew there'd be a complaint or lawsuit if they didn't come in high. Clearly the second appraiser was influenced to come in over market value. In the appraiser's eyes he has much to lose coming in at market and much to gain by coming in above market. That's all fine until the borrower goes under and the gov reviews the appraisal in default which they stated they will do. This is a concern because the current economy and real estate market is going down. People are losing jobs as interest rates rise. More homeowners could end up under water and in default. 

Things are a little similar to the beginning of the Great Recession. We all know what happened after the Great Recession. The gov pushed appraisers to come in high to meet higher values. After values dropped the government blamed appraisers! We report values. We don't set them. The gov caused the huge run up with reduced financial regulations and programs which helped lower income people take on loans they couldn't easily afford. The gov caused great financial damage to the people they said they were helping.

Image above came from this article
https://www.fanniemae.com/research-and-insights/perspectives/opportunities-improve-value-appraisals

Nice quote from the above linked article, "Reforms following the 2008 housing crisis attempted to improve the independence and accuracy of appraisals, and some early research indicated these reforms were marginally successful, with the percent of transactions confirmed falling from a high of 98 percent in 2007 to 94 percent in 2009. Confirmation rates, however, have since drifted back up as we have moved further away from the financial crisis."

So was it the financial crisis or reforms which caused change in % of appraisals meeting contract price?

What's interesting is there were appraisals done pre and post contract. When the appraiser knew the contract price, the value was more likely to meet or exceed that contract price. Maybe appraisers shouldn't know the contract price because it clearly influences them. Fannie Mae even makes that suggestion in their article.

Fannie Mae knows the industry and what's really happening. They can't speak freely because they are dependent upon HUD and the government no matter how "independent" they claim to be. For this reason they kiss HUD's ass and support all this false alleged appraisal bias. AEI's research has shown there is no appraisal bias based on race in the government's own data. HUD still falsely insists there is for political reasons. 2024 elections are coming. I bet Dem candidates will still be hawking racial appraisal bias in their campaigns to get the black, brown vote. They will claim they already solved most of the alleged bias but will continue to do more.


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html