State Appraisal Fee Surveys: In Search of the Elusive Customary & Reasonable Residential Appraisal Fee

Transcription

1 State Appraisal Fee Surveys: In Search of the Elusive Customary & Reasonable Residential Appraisal Fee Herb Holloway Research Economist Southeastern Louisiana University Business Research Center

2 Southeastern Louisiana University Business Research Center (BRC) The BRC is a partnership between Southeastern s College of Business and Department of Economic and Business Development Located in the Southeast La. Business Center 1514 Martens Drive Hammond LA (985)

3 The BRC provides economic and demographic data for the Northshore region of Louisiana and applied research wherever needed Economic Reporter newsletter Community commerce studies Economic impact studies Demographic/market analysis GIS Mapping Contract research projects

4 Timeline of BRC s involvement Initially contacted by board member of LREAB in August 2011 Submitted proposal in response to LREAB RFP in October 2012 Signed contract for 2012 LA study in Dec Conducted 2012 LA survey 2/13 3/31/13 Completed 2012 LA study in May 2013 Conducted 2013 LA survey 2/27 4/15/2014 Completed 2013 LA study in May 2014 Opened 2014 KY survey sites on 1/7/2015

5 Title 12 Banks and Banking Chapter X BUREAU OF CONSUMER FINANCIAL PROTECTION Part 1026 TRUTH IN LENDING (REGULATION Z) Subpart E Special Rules for Certain Home Mortgage Transactions Section Valuation independence Sub-section (f) Customary and reasonable compensation. (1) Requirement to provide customary and reasonable compensation to fee appraisers. Paragraph (f) (3) Alternative presumption of compliance states: A creditor and its agents shall be presumed to comply with paragraph (f)(1) of this section if the creditor or its agents determine the amount of compensation paid to the fee appraiser by relying on information about rates that: (i)is based on objective third-party information, including fee schedules, studies, and surveys prepared by independent third parties such as government agencies, academic institutions, and private research firms; (iii) excludes compensation paid to fee appraisers for appraisals ordered by appraisal management companies

6 LA 2012 Survey Design Both lender and appraiser surveys were online surveys hosted by QuestionPro Both included background questions on experience, volume, position, type of employer, etc. Lenders not involved in mortgage lending and appraisers not licensed in 2012 were diverted to end of survey (no fee data) Lenders who only ordered AMC appraisals and appraisers who only did AMC appraisals in 2012 were diverted to end of survey (no fee data)

7 Best laid plans Original plan for the official 2012 LA study was for a lender survey only Appraiser survey added at request of LREAB for comparison and for their private use Lender survey introductory sent to 1,359 lender contacts LBA members Lender survey announcement & link sent to 1,216 contacts LBA members Multiple reminders 143 valid lender responses/113 involved in mortgage lending less 45 w/ all AMC appraisals/68 who could provide non-amc fee data/61 who did

8 Appraiser s sent to 742 certified/licensed appraisers on LREAB contact list 415 total/383 usable responses (51.6% usable response rate) Fee data provided by 338 of the 383 So, the decision was made to combine lender responses and appraiser responses into one report

9 Share of respondents by % of non-amc work Table 1. Percentage of mortgage loans processed in 2012 for which appraisals were ordered directly from licensed appraisers (i.e., not routed through an AMC). % of Appraisals Ordered Directly from Appraisers Count % 0% (All appraisals ordered through AMCs) % 25% or less % 26-50% 8 7.1% 51-75% 4 3.5% 76-99% % All (100% ordered from licensed appraisers) % Total % Table 12. Percentage of 2012 residential appraisals done directly for clients (not routed through AMCs). Percentage of non-amc Appraisals Count % 0% - All for AMCs % 25% or less % 26-50% % 51-75% % 76-99% % 100% - All ordered & paid for by clients % No Response 3 0.8% Totals %

10 Fee data collected for: 64 parishes Five appraisal types Form 1004 (Full appraisal) Form 1004 FHA (Full appraisal for FHA) Form 1025 (Small (1-4 units) residential income property appraisal) Form 1073 (Indiv. condominium unit appraisal) Form 2055 (Exterior-only inspection appraisal) Three location types Urban, Suburban, Rural

11 Louisiana Median Appraisal Fees: 2012 Table 13. Median appraisal fees by type of appraisal:2012 (statewide/all locations). Form 1004 Form 1004 FHA Form 1025 Form 1073 Form 2055 n 4,856 3,680 2,594 2,240 3,078 Median * $450 $550 $425 $325 * Compare to Louisiana s statewide median from Mercury Network s Appraisal Fee Reference (February 2010) of $375

12 Table 14. Median appraisal fees by type of appraisal and location:2012 (statewide). Form 1004 Form 1004 FHA Form 1025 Urban Suburb. Rural Urban Suburb. Rural Urban Suburb. Rural n 1,464 1,799 1,593 1,146 1,369 1, , Median $450 $425 $450 $450 $525 $525 $550 Form 1073 Form 2055 Urban Suburb. Rural Urban Suburb. Rural n , Median $425 $425 $450 $325 $325 $350

13 Form 1004 (Suburban) Fees by Experience of Appraiser $440 $430 $420 $410 $390 $431 n=11 (42) $413 n=77 (418) $426 n=62 (333) $435 n=73 (366) $417 n=95 (338) $425 n=11 (42) n=77 (418) < 5 years 6-10 years years years 26+ years n=62 (333) n=73 (366) n=95 (338) $380 Mean Median

14 Geographic Market Areas

15 Figure 10. Form 1004 Median Appraisal Fees by Region and Location $550 $500 $450 $425 $450 $425 $425 $425 $450 $425 $425 $450 $450 $450 $350 $300 $250 $200 Urban Suburban Rural $150 $100 $50 $0 Region 1 Region 2 Region 3 Region 4 Region 5 Region 6 Region 7 Region 8 Region 9

16 Appraiser, Lender, & Combined Responses Form Urban Region 1 Region 2 Region 3 Region 4 Region 5 Region 6 Region 7 Region 8 Region 9 Statewide Appraisers: n ,230 Mean $401 $433 $418 $431 $433 $469 $418 $447 $423 $425 Median $450 $450 Lenders: n Mean $396 $390 $403 $414 $399 $404 $415 $382 $415 $402 Median Appr - Lndr: Mean $5 $43 $14 $17 $34 $66 $3 $64 $7 $23 Median $50-0- $ Combined: n ,464 Mean $401 $428 $416 $428 $423 $447 $417 $420 $422 $421 Median $425 $425 Comb - Lndr: Mean $5 $38 $13 $14 $24 $43 $2 $38 $7 $19 Median $25-0- $

17 2013 Louisiana Survey No changes to survey instrument except adding additional choices to background questions Lender introductory (2/21/14), announcement (2/27), and reminder s (3/17 and 4/1) sent to ~1,200 in-house contacts and 1,050 LBA members Announcement also sent to 150 members of LMLA on 4/3/14 Multiple reminders Survey site closed on 4/22/14 97 valid lender responses/81 involved in mortgage lending/61 with non-amc appraisals/47 provided fee data (compared to 61 for 2012)

18 Appraiser responses: 280 total/250 usable/224 provided fee data (compared to 338 for 2012) Overall median fees unchanged for 1004 FHA and 1025; up $25 for 1004, 1073, and 2055 Median appraisal fees by type of appraisal: 2012 & 2013 (statewide/all locations). Form 1004 Form 1004 FHA Form 1025 Form 1073 Form $450 $550 $425 $ $425 $450 $550 $450 $350

19 2014 Kentucky Appraisal Fee Survey KREAB sent out introductory to their membership list (~1,565) on 12/1/2014 BRC collected addresses for 520 mortgage lenders from MBAKY, MBA of Louisville, MBA of Lexington, LBAR, Zillow, etc. Announcement s sent to KREAB and lender lists on 1/7/2015 Reminders sent out on 1/15/2015 to 1,490 appraisers and 450 lenders Larry Disney spoke to MBAKY Board on 1/15 As of 1/23, 257 appraiser & 9 lender responses

20 Very similar to LA survey add Form 1004C Regions? For this study, we found it useful to subdivide the Kentucky into nine economic regions. The regions roughly correspond to labor, housing, and retail markets --Coomes, Paul. Improving Earnings per Job: The New Economic Development Challenge in Kentucky. CBER, Center for Business and Economic Research, located at the University of Kentucky, Gatton College of Business and Economics.

21 Thoughts, questions, etc.??? Herb Holloway Southeastern Louisiana University Business Research Center (985)