Certain states require AMC staff to receive training to ensure they understand valuation independence regulations as well as other statutory requirements. Our free webinar, “Components of AMC Training” will be held on June 10th at 2 pm with Josh Walitt as the host. This webinar will hit on certain key topics, giving attendees an overall grasp of which processes and issues are impacted by valuation independence, USPAP, discrimination regulations, and more. We sat down with the host, Josh Walitt, to discuss his upcoming webinar and what we can expect from “Components of AMC Training” on June 10th at 2 pm. Can’t make the time? Register to receive the full recording in your inbox as soon as it’s over!
Buzz: Can we have your background in the industry?
Josh: I am a compliance and valuation consultant based in Colorado. I provide services to appraisers, banks, technology firms, education providers, appraisal management companies, and attorneys. Depending on the client’s needs, my work includes coaching, customized training, quality assurance, continuing education, disciplinary action assistance, internal audit, and other customized projects. For appraiser clients, we commonly focus on proactive practices, methods and support, investigations, use of assistants, workflow efficiency, and technology.
To this point in my career, I’ve filled a variety of roles, including fee appraiser, national compliance manager, member of the Colorado Board of Real Estate Appraisers, and member of the Colorado AMC Rulemaking Task Force. In 2015, I designed the Market Machine, a technological tool used by appraisers and other valuation professionals. I hold the SRA and AI-RRS designations with the Appraisal Institute, am a member of the National Association of Appraisers (MNAA) and serve on their national Board of Directors, hold a Certified Distance Education Instructor (CDEI) certificate, am an AQB Certified USPAP Instructor, and am an Appraisal Institute approved instructor. I have also served as the Chair and Co-Chair for the Agency Relations Committee of the Collateral Risk Network.
Buzz: What is the focus of Walitt Solutions’ Annual Compliance Training course?
Josh: The course is taken by staff of lending institutions and appraisal management companies and centers on the need for companies to meet or exceed clients’ and regulators’ minimum training requirements. Main topics include how to apply regulatory requirements and best practices to assigning appraisals, managing orders, screening reports, making payments, interacting with appraisers and clients, understanding USPAP, and examining abuse and discrimination, as they relate to the valuation process, valuation independence, and appraisers.
Buzz: Why do AMCs need the training?
Josh: The Annual Compliance Training is designed to meet requirements of clients and regulators. For example, certain states require AMC staff to receive training to ensure they understand valuation independence regulations as well as other statutory requirements. In fact, some states have very specific content requirements for the training. And, of course, federal regulations and guidelines establish the need for institutions and their agents to have an understanding of the appraisal management process to avoid violations. Additionally, client contracts often require that appraisal management companies ensure staff receive proper training on various topics.
Companies may not be confident their own on-the-job training meets the requirements of their clients and regulators. They are often more confident in having a training certificate issued by a third party, rather than discovering their own training may not be effective or even compliant with requirements. We continue to provide this training to AMCs and lenders, and have even customized for several clients.
Buzz: What are the duties of an appraisal management department?
Josh: Appraisal departments, whether at an appraisal management company or a lender, have many responsibilities related to the process of obtaining appraisal reports that can be used for mortgage transactions. Staff must be versed on proper procedures related to appraiser applications, panel management processes (e.g., adding, removing), selecting appraisers, appraiser compensation, quality control of reports, mandatory reporting, revision requests, complaints, and how to handle alleged or suspected violations of valuation independence. Something as simple as mishandling a phone call, misstating a fee, or requesting a revision incorrectly can lead to problems and consequences.
In the end, as I often state during the training, appraisal departments must ensure they are, one, engaging qualified appraisers and then, two, stepping back to allow the appraiser to fulfill his or her function in an independent manner. If both of those measures are not met, you’re going to have problems.
Buzz: Will you be addressing how an AMC handles cancelling and reassigning assignments, violations of valuation independence, and other communications with the appraiser?
Josh: Yes. The full five-hour Annual Compliance Training course covers many topics, including those you mentioned. The training provides staff a good top-of-mind awareness related to many issues they must have knowledge of.
Buzz: What staff should receive the training?
Josh: Staff members at AMCs and financial institutions who engage appraisers, manage orders, recruit appraisers, request revisions, review reports, handle escalated issues or complaints, pay appraisers, or are a controlling person or manager should receive this type of training.
Buzz: What is the process for assigning appraisers to an assignment and what is the criteria used?
Josh: Even before assigning an appraiser to an order, an appraisal management department must ensure certain minimum requirements have been met, to even be part of the panel. Then, at the time of assigning, staff should consider factors like past performance, complexity, qualifications, type of credential, status, and other characteristics that relate to the assignment and the appraiser. We also address how to handle scenarios where a party, such as a loan officer or listing agent, attempts to select or deselect the appraiser.
Buzz: How can revision requests be interpreted as a violation of valuation independence?
Josh: Many times, alleged violations of valuation independence result from staff instructing the appraiser on value, adjustments, comp selection, and property ratings. It’s perfectly acceptable for an appraisal management department to question the appraiser’s process or report and to ask for more explanation or support. However, in general, staff should avoid instructing appraisers on these types of items. Attendees leave the course understanding the three categories that every revision request must fall into.
Because so much of the interaction between appraisers and appraisal management departments relates to revision requests, we spend a lot of time discussing scenarios throughout the course.
Buzz: How should AMCs handle a reconsideration of value (ROV)?
Josh: If the AMC knows how to handle a revision request, they already know how to handle a reconsideration of value (ROV). That’s because a reconsideration of value is merely a specific type of revision request. When we consider the regulations from a practical perspective, reconsiderations of value are simply revision requests that relate to value. Regulations do not differentiate between a value-related revision request and non-value-related revision request.
Buzz: What are the USPAP considerations an AMC should always keep in mind?
Josh: The course includes a high-level overview of the Definitions, Rules, and Standards, and other information related to USPAP, such as Advisory Opinions. This approach gives the attendees a good understanding of appraisers’ perspectives when they are interacting. For example, understanding when a new assignment is established and what exactly that means to both the appraiser and the AMC is necessary if you want a successful, efficient, and compliant relationship.
Keep in mind, the course shouldn’t be confused with a USPAP Update Course. While I enjoy teaching USPAP to AMCs and financial institutions, this Compliance Training course and the USPAP Update Course are not substitutes for each other.
Buzz: Does the course only focus on valuation independence issues?
Josh: No, the course also focuses on other regulations that clients expect AMCs to train their staff on, such as UDAAP, ECOA, and Fair Housing. Especially considering clients’ and regulators’ concerns regarding discrimination and deceptive practices, it makes sense to devote part of the course to related regulations. The course includes explanations of the regulations, high-level enforcement actions that have taken place, and appraisal-related scenarios.
Buzz: How does the upcoming webinar compare to the actual four-hour training?
Josh: The 45-minute webinar will hit on certain key topics, giving attendees an overall grasp of which processes and issues are impacted by valuation independence, USPAP, and discrimination regulations. The webinar also gives attendees a chance to ask questions. The registration for the webinar is accessed by going here.
The full five-hour course provides training on the specific information, scenarios, and issues required by clients and regulators. It is a great opportunity for AMC and lender staff to learn and ask questions. Attendance certificates (non-CE) are issued so companies can document the topics covered and track their staff members’ training for audit records.For the full class, registration for classroom, live online, and self-paced online delivery options are found here.
We appreciate Josh taking the time to answer our questions about his free upcoming webinar, “Components of AMC Training” on June 10th at 2 pm.