CSS Appraisal Compliance Guidelines

Appraiser Approval

All appraisal vendors utilized by CSS are selected based upon a thorough review of their education, training, work experience, and licensing standards.  CSS is committed to providing customers with exceptional service through the delivery of quality appraisal products and services on a consistent and timely basis.

Requirements for Approval as a CSS Appraiser:

  • A minimum of three years, full-time, field appraisal experience
  • A current State Appraisal license/certification
  • No infractions or violations that have resulted in sanctions from any State Appraisal Board or Financial Regulatory Agency
  • Must not have been convicted, found guilty, regardless of the penalty of a misdemeanor involving moral turpitude or of any felony
  • Error and Omissions Insurance
  • Copy of State License / Certification
  • Federal Tax Code form W-9, Taxpayer Identification Request

Procedures:

  • Completion of an appraiser application, which includes:
    • Background
    • Business and personal references
    • Electronic Capabilities
    • Scope of geographical coverage and knowledge of area
    • Turnaround time and pricing
  • Resume, to include:
    • Pertinent experience
    • Formal education
    • Employment history
    • Names of the appraisal organizations of which appraiser is a member

Appraiser Selection Process

The CSS appraiser database houses thousands of residential appraisers nationwide that are ranked by their overall performance.  In addition to the current database, CSS has several other methods for locating qualified appraisers through extensive recruiting efforts.

An appraiser is selected for an assignment based on the following criteria (not necessarily in this order): 

  • Experience with specific property/product type
  • Geographic competency in subject property location
  • Proximity to the subject property
  • Overall performance ranking:
    • Turnaround time on current and previous assignments
    • Capacity and current open units
    • Quality and error rate of assignments completed
  • Response time and follow up
  • Professionalism
  • Ability to follow instructions
  • Electronic capabilities
  • Meeting the state’s continuing education requirements for licensed / certified real estate appraisers

Appraiser Guidelines and Expectations

To ensure compliance in servicing an appraisal assignment, CSS provides to every appraiser, prior to placing an order and with every order, specific information pertaining to industry standards and guidelines, CSS’ expectations, and the customer’s individual specifications.

Corporate Settlement Solutions’ Requirements and Expectations for all appraisal orders:

  • All appraisals must adhere to and comply with:
    • FNMA / Federal National Mortgage Association (Fannie Mae)
    • FHLMC / Federal Home Loan Mortgage Corp (Freddie Mac)
    • FIRREA / Financial Institution Reform, Recovery, and Enforcement Act
    • USPAP / Uniform Standards Professional Appraisal Practice
    • Dodd-Frank Wall Street Reform and Consumer Protection Act
    • Department of Treasury Interagency Appraisal and Evaluation Guidelines
    • GLB Act / Gramm-Leach-Bliley guidelines and standards
    • Any other specific requirements reflected on the order
  • Appraiser acceptance of an assignment acknowledges that their license is active and in good standing and that they are not reflected on exclusion lists for FNMA, FHLMC, HUD or this specific Lender.

Quality Control Overview

CSS employs a multi-tiered quality control process designed to deliver consistently high-quality valuation products to our customers.

TIER ONE:  The first stage of our quality control process is to run the appraisal report through an automated, rules-based review tool.  This tool contains several hundred rules and checks to ensure that many of the factual items in the appraisal report are consistent and complete.  The rules contained in the automated tool are based on standard Fannie/Freddie appraisal guidelines as well as the standard mathematics and consistency checks for the appraisal report.  The rules differentiate between those report elements that are critical and those that trigger follow-up items.

For example, if the appraiser omitted to note in the Neighborhood Analysis whether property values were increasing, stable, or declining, the tool would note the omission as something that must be fixed before the report can be passed.  If the appraiser noted that property values were declining, the tool would provide a note to the reviewer that he or she should be looking for a comment that explains why property values are declining.  In other words, there are stops and notes to the reviewer generated by the automated tool.

TIER TWO:  For select appraisal reports, the next stage is utilizing Platinum Data Solutions’ (PDA) RealView® quality control product.  PDA states: “Sourcing more data more accurately than any other solution of its kind, RealView® is the revolutionary business rules engine that rapidly processes and analyzes appraisals for compliance, completeness, and consistency versus appraisal industry guidelines and the client’s customized appraisal review rule set. This innovative, configurable and highly sophisticated platform significantly enhances appraisal quality control and assurance, empowering Mortgage Lenders, Insurers, and Compliance Agencies, Servicers, AMCs, Credit Unions, Banks, Thrifts and Investors to thoroughly and quickly review appraisals with a significant reduction – as much as 60% – in review time and errors.

During the automated review process:

  • 2,500+ business rules and USPAP guidelines reviewed
  • 1300+ specific data points analyzed
  • Appraisal information compared to custom review rule set(s) established by the client, lenders, investors, etc.
  • Exceptions to the custom appraisal review rule set, communicated directly to impacted parties — appraiser, reviewer, lender — so necessary actions can be taken to speed the completion of high-quality appraisals
  • Appraiser license status verified
  • Public record, local listing, and pending sale data gathered and provided for additional insight on trends and comparables
  • Sales price movement, market risk, and potential mortgage fraud detected”

TIER THREE:  Once the appraisal report passes through the automated tools, a reviewer then takes over, reads the automated feedback to determine what must be fixed or revised, and ensures that the consistency checks are contained in the report.  The key function of the human reviewer is to focus on those elements of the appraisal report that are subjective and whether the appraiser has presented a logical, sequential analysis of the subject property that leads the reader/user of the appraisal report to a logical value conclusion.  We should note that should the customer have specific appraisal requirements beyond those contained in the Fannie/Freddie guidelines, we incorporate those standards into our review process.

Generally, the Appraisal Reviewer is a licensed or certified appraiser, but all of our Appraisal Reviewers are trained and experienced in performing an administrative quality control review of the appraisal.  Once an appraisal report has successfully passed through this process, it is ready for delivery to the customer.  Should the customer have a post-delivery question or require additional information on the report or the property, Corporate Settlement Solutions will process that request expeditiously through our QC unit to ensure that the customer’s loan underwriting process is not unduly delayed.

Due to the nature of our quality control process, there should be no “Unacceptable” ratings once a report is delivered to our customer.  It should be noted that our quality control process is not a substitute for the lender underwriting the appraisal for a specific loan program or product where the lender’s internal risk management and credit policy standards must enter the decision making process.

Payment of Appraisers

 CSS pays its appraisers Customary and Reasonable fees which are determined by the appraiser.  As with all its vendors, CSS pays its appraisers for invoiced work twice each month.

Customary and Reasonable fees paid to Appraisers

Regulation Z requires the lender and its agents to compensate a fee appraiser at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised.  The regulation outlines a two-step process for determining customary and reasonable rates:  (1) recent rates for comparable appraisal services in the relevant geographic market must be identified; and (2) factors such as type of property, scope of work, required turn-time, appraiser qualifications, experience, and quality, must be reviewed to make any appropriate adjustments to the identified rates to ensure the amount of compensation is reasonable.

Unfortunately, the CFPB has yet to provide any rule-making or guidance regarding this subject matter.  Few states have conducted comprehensive customary and reasonable fee studies.  When such studies have been adopted, CSS follows those guidelines.  Pending adoption of additional studies or further direction from the CFPB, CSS has approached compliance in this area by simply asking each appraiser added to our network, “What are your fees to produce this appraisal product?”  Whatever fee is quoted by the appraiser is the fee we pay that appraiser.

Appraiser Independence Requirements

Prior to commencing work for any lender, CSS conducts an “onboarding” conference outlining the role and responsibilities of CSS and the lender with respect to communication with appraisers and compliance with Appraiser Independence Requirement (“AIR”) provisions. Once work begins, CSS continuously monitors communications with appraisers to ensure compliance with AIR provisions. Any incidents which appear to compromise compliance are escalated for resolution to Sherri Zahtilla, VP Valuation Services.

Appraisal Revisions and Disputes

If Customer has additional information it would like reviewed once an appraisal has been completed and delivered, Customer should contact CSS appraisal staff via email, website, or telephone with the specifics of the request.  Any and all information that is provided to CSS will be reviewed, shared with the original appraiser and followed through to resolution. If the outcome changes any information within a completed report, a corrected report will be issued.

If there is an actual appraisal value related dispute, versus a minor correction, CSS will research the matter further and have the appropriate corrections made and/or provide more information that aids in justifying the value initially provided.

While we understand that a borrower may not always be happy with their final reconciliation of value, our dispute resolution process includes providing additional explanatory information to the borrower such as specifics on the discrepancies/errors within the appraisal report highlighting the subject characteristic (wrong # of rooms, more sq. ft., etc), or by providing additional sales comparables not previously used.

Removal of Appraisers

In the event the performance or conduct of a specific appraiser warrant the removal of the appraiser from consideration for future appraisal assignments, CSS complies with all applicable state and federal guidelines governing the removal process. Often, this will involve providing timely notices pursuant to state Appraisal Management Company laws.

Conclusion

The CSS Appraisal Compliance Guidelines set forth above are intended to ensure the lender receives timely, accurate and compliant appraisals from CSS for each and every appraisal order. Additionally, this documentation is intended to assist lenders in meeting their obligation to demonstrate the appraisal management services provided by CSS are performed in a safe and sound manner consistent with all applicable laws and regulations.