To better protect our nation from predatory lenders & negligent, deceptive appraisal practices, I believe the Federal Government should require Appraisers to provide copies/proof of the MLS (Multiple List Service) Sold Sheets of the subject & comparables used in the appraisal. Also, to provide Assessor Records/proof as to what is written within the appraisal report. Without these documents neither HUD/FHA, nor lenders have any way of verifying information within an appraisal. We as Appraisal Reviewers do not always have access to MLS & Assessor Records due to lack of funds. Whereby, an appraiser can make up home sale addresses, phony sales prices, give erroneous sq. ft. & year built of homes, disregard seller concessions, and not report prior listings, or prior sales of homes. Some business partners of MLS & municipalities will give the needed copies free of charge when requested by a reviewer, but many do not. The AVM (Automated Valuation Models) sometimes used to base appraisals & appraisal reviews, are not available in certain areas, lack much information, and are very risky to use. In an effort to shorten up my memo I have cut out many of the “WHYS”.
Idea No. 97