Monday, December 20, 2010

Uniform Appraisal Dataset Specs - FNMA

New reporting requirements for appraisals delivered to Fannie/Freddie effective March 19, 2012 have been published.

First quote from the document:

"Under the direction of the Federal Housing Finance Agency (FHFA), Fannie Mae and Freddie Mac (the GSEs) have developed the Uniform Mortgage Data Program (UMDP) to enhance the accuracy and quality of loan data delivered to each GSE. The Uniform Appraisal Dataset (UAD) is a key component of the UMDP, defines all data points required for a complete appraisal report form, and standardizes key appraisal data elements for a subset of fields on the Fannie Mae and Freddie Mac uniform residential appraisal report forms.

For conventional loans delivered to the GSEs on or after March 19, 2012 (and with application dates on or after December 1, 2011), Fannie Mae and Freddie Mac will require lenders to deliver electronic appraisal data prior to the loan delivery date. The appraisal data must conform to UAD and be delivered through the Uniform Collateral Data Portal (UCDP). The UAD and UCDP will help lenders, the GSEs, and other industry participants manage collateral risk through efficient collection and use of high-quality appraisal data."

The rest from Michael Imes:

"If you are interested in letting FM know how you feel, the link for feedback is below. I also included my comments fyi. FNMA doesn’t have an email address or form I can find to send in comments. They obviously don’t want to hear from anyone. I wonder why?

Topic: UMDP

Why isn't there a comment period from the industry...say appraisers to begin with, then lenders who have to try and read their appraisals?!?

You are recreating a wheel that has already been created by Marshall and Swift (M&S). Why didn't you use things that are already in place? Your system has some issues.

1. You are trying to change something that doesn't need changed, just specified. M&S already has these categories, so it is obvious where you got them from, but why can't you go ahead and use what makes sense? The standard word descriptors or the numbering system M&S uses? This would make much more sense. Everyone would understand it and be able to use it without much change. Instead, you decide to create more hardship.

2. You are using a ranking system that is opposite from what is already in place. This is going to cause much confusion.

3. You didn't leave room for that property that fits in the middle. M&S has a numbering system I am sure you are aware of (1.0, 1.5, 2.0, etc.) that accounts for those properties that don't quit fit into either category. Maybe we ought to rethink your move here? This is going to create so many headaches with lenders and appraisers. It also begs the question, does the appraiser assume/round to the higher or lower designation? Oh yes, higher and lower don't mean anything now...better or worse designation?

4. Has anyone mentioned how a "subject to" appraisal should be notated? The guidelines tell appraisers to tell you the actual condition/quality. But what if it is subject to? Do they tell you the before or after? Many will ask, be prepared.

I suggest you reopen, excuse me, open it to public comment rather than be dictators. Try working with the industry instead of against it which is what this readily demonstrates. Doesn't everyone want something easier to use that is more transparent rather than more difficult with more chances of errors? I agree that you all need to make this move. I don't agree with how you have gone about doing it, or how you did it. Again, get some feedback from the industry. Work with others rather than against them.


Michael Imes, IFA"

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