The Consumer Financial Protection Bureau wants you to see the full appraisal report on the house you’re buying or refinancing as early in the mortgage process as possible, and without your having to ask the lender for it.
This means all the “comparable” properties the appraiser selected, adjustments for property condition or location, plus all additional data – especially computer-generated estimates – that may have been used to arrive at the final value. It also means you would get to see who performed the appraisal and whether he or she is merely licensed in the state or carries a professional designation – letters such as “SRA” after the name indicating higher levels of training and experience. Plus it would give you an idea about whether the appraiser is locally based and thus knowledgeable about neighborhood sales and listing trends, or has traveled from another part of the state.
Information like this can be crucial in an environment in which home sellers, buyers and realty agents routinely complain about botched appraisals that complicate or kill deals by coming in thousands of dollars below the contract price. In many cases, critics say, appraisers continue to inappropriately select distressed-sale comparables to value non-distressed transactions in areas where property values are now rising. In a May survey of its members, the National Association of Realtors found that 33 percent of agents reported problems connected with appraisals that endangered sales.
The consumer bureau also wants to open the door to disclosure of fee-splitting information that typically is kept hidden from you: How much of your $450 to $600 in appraisal charges at closing will go to the appraiser, and how much to an unseen appraisal “management company” that may be owned by or affiliated with your lender and is also getting a cut of the action?
In a proposal Aug. 16, the bureau said that under its plan, mortgage lenders would be required to provide copies of all written appraisals and other data used in the valuation “promptly after receiving them,” but in no event later than three business days prior to the closing. This would include the electronic “automated valuation models” (AVMs) widely used by lenders and management companies to supplement standard reports.
AVMs, which depend on public records rather than on-site observations, have been criticized by some appraisers and realty agents as being tools to keep appraised values below contract prices agreed upon by sellers and buyers in rebounding markets. Banks defend their use as safeguards against overvaluation and subsequent losses in the event of default.