Tuesday, December 5, 2023 | The Latest Buzz for the Appraisal Industry

Making Appraisal Reform Part of Housing Finance Reform

Appraisal Reform

(Editor’s Note: This article originally appeared in the Spring 2017 issue of Appraisal Buzz Magazine)

A new administration and Congress took office in January, renewing the hope for long-awaited housing finance reform. Such reform is the unfinished business from the financial crisis that began before the Obama administration took office. Today, Fannie Mae and Freddie Mac remain in government conservatorships and American taxpayers remain the equity support for more than half of the U.S. mortgage market.

Reduced to its essence, housing finance reform’s primary component involves shifting to private investors some $5 trillion of mortgage credit risk currently on the balance sheets of Fannie Mae and Freddie Mac. Every significant legislative proposal for reform would shift (at least) all but the tail risk to such investors.

This raises an issue for the investment community that directly affects appraisers.  Since reform would create a new asset class in mortgage credit risk, investors in this asset class should care a lot about collateral risk. What is the value proposition for appraisers in assessing and communicating information about collateral risk to investors?

The liquidity and stability of this new credit market will be strengthened the more that uncertainty can be reduced.  Collateral risk is one source of uncertainty that could be reduced if we can answer the following:

  1. What data and analytics should appraisers produce as part of developing their opinion of value that would enhance investors understanding of collateral risk?
  2. What changes to the appraisal report would capture this new information and how can it be conveyed to credit investors?
  3. How could appraisers update certain key information on collateral risk over the life of the loan so investors can be informed of changes in collateral risk? How would appraisers be compensated for such work?

The last question might be best answered on a market-by-market basis not loan-by-loan. But the first two speak directly to conveying more information from appraisers to investors than simply a point value estimate of current market price.  Indeed, the first two questions get to the original purpose of an independent appraisal — an opinion of underlying value, not just an assessment of current market price.

Credit investors are continually making risk assessments.  A simple snapshot of market price is insufficient to tell investors how sustainable, or stable, today’s market price is.  Investors want to know something about the house value should the borrower default and they need to foreclose on the property.  As one example, some estimate of the range of possible value, or of a confidence interval around the value estimate, could be useful.  So, we need to ask better questions of appraisers to get those answers.  And we need to better equip appraisers, whether with data, analytics, training, or compensation, to produce that kind of value for investors.

Housing finance reform also involves rethinking our regulatory infrastructure and legal framework.  Certainly, the appraisal arena is in need of modernization in those areas. Instead of a subcommittee of the Federal Financial Institutions Examination Council (FFIEC) co-managing oversight responsibility, there needs to be a single regulator in charge and empowered. My personal preference is for the Federal Housing Finance Agency to be charged with establishing a Chief National Appraiser position and the FHFA assuming responsibility from the FFIEC.  Whatever the particular solution, the lack of clear federal leadership in this area should be addressed as part of housing finance reform.

Recognizing that the current state of affairs creates many pain points for the appraisal community, I believe that opportunity exists for appraisers to be part of a constructive dialogue of how the industry can serve the needs of a reformed housing finance system.

Have content of your own that you would like to submit? Email comments@appraisalbuzz.com.

Mark Buhler

The Surfing Appraiser

Riding the waves of the appraisal profession can result in a range of outcomes and emotions over time. Appraisers, and surfers, have varying levels of

Read More »
Timothy Andersen, MAI, MSc., CDEI, MNAA

“Naked, Unarmed, and Alone?”

Question: “My state board recently charged me with authoring a misleading report. I got the client to write a letter to the state indicating my

Read More »