Editor’s Note: In life after Collateral Underwriter (CU), appraisers are eager to understand how they can create statistical support for their adjustments and value results. In this story, author James Swartz provides a good primer for understanding regression and appraising.

Appraising with Regression
By James A Swartz, PhD.

As a real estate appraiser, you are interested in determining how a set of characteristics such as the number of baths and bedrooms, total s As a real estate appraiser, you are interested in determining how a set of characteristics such as the number of baths and bedrooms, total square feet, and others, affects the value of a property.

Property characteristics that affect value are called independent or predictor variables because they help predict what the property is worth. An estimated sales price is called the dependent variable because it depends on the predictor variables.

One statistical tool used to estimate value is called regression analysis. Regression techniques have long been central to the field of economic statistics (“econometrics”). Increasingly, they have become important tools for appraisers as well.

In an appraisal regression model, the dependent variable or sales price is “regressed” on a set of property characteristics to determine how much of the variation in the sales prices, of geographically comparable properties, are due to the variation in the set of property characteristics. The higher the percentage of variation in the sales prices of like properties that can be “explained” by the included set of property characteristics, the more accurate the prediction of the property value. A thorough regression analysis will therefore improve your ability to accurately appraise property values beyond what can be done by “guestimating” or looking at only one or a few property characteristics and comparing only a few similar properties.

The best way to begin to understand how regression modeling works in the context of property appraisal is to explain the approaches used and then walk through an example.

Regression Modeling Approaches
Let’s begin by analyzing a few different methods of regression analysis. Simple linear regression, also calledBivariate regression, assesses the relationship or association between a single dependent variable, such as a sales price, and a single independent or predictor variable, such as square footage.

Multiple linear regression assesses the relationship or association between a single dependent variable, such as sales price, and multiple independent or predictor variables, such as square footage, lot size and age of the property.

Hedonic regression is an even higher level of analysis because it can be used to estimate the contributory value of each property characteristic on an estimated property value. There are four steps in the process:

First, a group of properties in geographic proximity to the subject is selected from the MLS database. The number of properties selected for analysis should be large enough (no fewer than 200 properties) to allow for the examination of the variation in property characteristics as well as in sales prices. Greater variation in the characteristics studied is desired, rather than a narrow comp selection based on strict comparability, because greater variation improves the accuracy of the estimated effects on sales price for each characteristic across a broader range of possible values for that characteristic.

Then, a set of simple regression models is run using the selected properties. A separate simple or Bivariate regression (i.e., two-variable) is run for each property characteristic. Each simple regression is run on the full data set containing information on the 200+ properties. The purpose of this step is to screen for those property characteristics that can be reliably associated with variations in the sales prices of the properties in the data set.

In the third step of the process, those property characteristics that are found to be reliably associated (i.e., statistically significant) with the sales prices of properties, are included in a multivariable regression model (i.e., many variables). Using the full data set, the multivariable regression assesses the association between sales price, the single dependent variable, and a set of multiple predictors such as square footage, lot size, and age of the property.

This model determines how well the remaining property characteristics individually and as a set predict variation in sales prices. Importantly, the model examines the associations among the property characteristics themselves. Only those characteristics that uniquely predict sales price are retained in the model. Characteristics are dropped that overlap substantially with other characteristics already in the model. Only the best predictor set is retained.

In the fourth and final step, the appraiser selects a small subset (3) of properties comparable to the subject property. A map displaying properties by their proximity to the subject assists in this step. Using the predicted sales prices for these properties and the valuation for each property characteristic in the final multivariable model, a final value is obtained for the appraised property.

Overcoming Math Anxiety
People new to regression modeling often have questions about the technique and concerns about their ability to use and interpret the more complex but more accurate multivariable models. However, once a level of familiarity is developed and “math anxiety” is overcome, multivariable regression models become an indispensible tool for developing appraisals.

Although simple or Bivariate linear regression models are appealing because of their simplicity, they will not produce as accurate a result as a multivariable regression analysis for a number of reasons. First, the selection of which variable(s) to use might leave out potentially important factors. Second, Bivariate regression does not control for the associations among the predictor variables themselves. For instance, the number of bedrooms and square footage might both have a very strong association with sale price when considered independently in separate Bivariate models. When considered simultaneously in a multivariable model, the association of the number of bedrooms with sales price might not be as substantial relative to the association with square footage.

Multivariable models will automatically adjust for the interdependency of these two (or more) predictors while Bivariate models will not. As a consequence, if you use two Bivariate models to develop your estimate, you would overestimate the sale price because you would be giving too much weight to the number of bedrooms within the context of the property’s square footage. The degree of error introduced by adding together the results of Bivariate models increases as you consider more and more predictors. In the end, it is much easier to use a multivariable model to make the correct adjustments and estimate a value without having to do all of the tedious mental and mathematical work of combining separate estimates.

Remember, regression analysis is not a substitute for traditional appraisal practices as much as it is a complement to your experience and judgment. It will help you identify the most salient features for estimating the value for a given property, possibly including some you might not have thought were important but which turn out to be, based on sales of other properties in the same area.

About the Author
James Swartz, Ph.D. is an Associate Professor in the Jane Adams College of Social Work at the University of Illinois at Chicago. He obtained his Doctorate in clinical psychology from the Northwestern University Feinberg School of Medicine (1990) and also has a Masters degree in research methods and statistics from Loyola University of Chicago (1982). He has authored over 50 publications in peer-reviewed journals, the majority of which use advanced statistical analytic techniques.

http://www.nationalmortgagenews.com/news/origination/appraiser-shortage-could-gum-up-the-works-at-mortgage-lenders-1051403-1.html

The National Fair Housing Alliance and 19 local fair housing organizations are accusing Fannie Mae of widespread racial discrimination, claiming that the GSE maintains and markets its foreclosures in white neighborhoods “consistently better” than in middle- and working-class African American and Latino neighborhoods.

The groups filed a complaint with the Department of Housing and Urban Development, alleging that Fannie Mae’s neglect of foreclosures in minority neighborhoods in 34 metro areas is a violation of the federal Fair Housing Act.

The NFHA said that the complaint is the result of a five-year investigation into the property preservation methods used by Fannie Mae. In a release, the NFHA said that evidence gathered from 2010 through April 2015 shows an “ongoing pattern and practice of discrimination” by Fannie Mae and its asset management contractors.

“Fannie Mae is wreaking havoc on middle- and working-class communities of color nationwide through a pattern of neglect that is frankly appalling,” said Shanna Smith, president and CEO of NFHA.

“Fannie Mae’s failure to take care of its massive foreclosure inventory in African American and Latino neighborhoods further destabilizes the communities hardest hit by the foreclosure crisis, in clear contradiction of its congressional charter, federal fair housing laws, and its obligation to affirmatively further fair housing,” Smith continued. “This systematic failure also creates health and safety hazards, contributes to blight, and places an unfair burden on neighbors and city governments to clean up the problem.”

The complaintant groups (see below for full list) say they investigated 2,106 foreclosures owned by Fannie Mae in 34 metro areas that include 129 cities and found that properties in communities of color had broken doors and windows, unlocked doors and windows allowing access to the home, excessive litter, dead or overgrown lawns, dead animals or live animals on the property, and other major deficiencies.

When contacted about the allegations, Fannie Mae said that it believes the charges are without merit.

“We strongly disagree with these allegations and firmly believe they have no merit,” Fannie Mae said in a statement to HousingWire. “We are confident that our standards ensure that properties in all neighborhoods are treated equally, and we perform rigorous quality control to make sure that is the case. We remain dedicated to neighborhood stabilization efforts across the nation, including with respect to our maintenance of foreclosed properties.”

In the release, the NFHA said that since 2009 it made efforts to work with the GSEs to correct their property preservation practices.

“Freddie Mac looked into its practices and made good faith efforts to correct its business model, but Fannie Mae refused to take responsibility for its neglect in communities of color,” Smith said. “The difference between Freddie and Fannie properties is striking. We now rarely find disparities in Freddie Mac’s inventory. Fannie has to take responsibility.”

The groups said that they investigated foreclosed properties for “deficiencies” that would affect the properties’ marketability and visual appeal. Among those deficiencies are broken, boarded or damaged windows and doors; unlocked doors and windows; damaged and obstructed gutters and downspouts; safety hazards; accumulated trash; overgrown lawns and shrubs; lack of “for sale” signs; and others.

According to the result of the groups’ investigation, 49.5% of the foreclosed properties in White communities had fewer than 5 deficiencies, while only 24.4% of the foreclosed properties in communities of color had fewer than 5 deficiencies.

The groups also said that 22.1% of the REO properties in communities of color had 10 or more deficiencies, while only 8% of the REO properties in predominantly White communities had 10 or more deficiencies.

The groups say there neglected properties in the following cities: Hartford, Connecticut; Indianapolis; Greater Palm Beaches, Florida; Grand Rapids and Muskegon, Michigan; Orlando; Vallejo, Richmond and Oakland, California; New Orleans and Baton Rouge, Louisiana; Chicago; Miami; Richmond, Virginia; Atlanta; Milwaukee; Baltimore; Charleston, South Carolina; Kansas City; Las Vegas; Memphis; Minneapolis; Philadelphia; Phoenix; San Diego; Tucson, Arizona; Washington D.C.; Prince George’s County, Maryland; Dallas and Fort Worth, Texas; Gary, Indiana; and Cleveland, Dayton; Toledo and Columbus, Ohio.

“Fannie Mae has not only ignored the problem but has continued to award millions of dollars in new contracts to the same asset management companies that engaged in this discriminatory behavior,” Smith said. “We have filed this complaint after having exhausted every possible means we could think of to get Fannie Mae to abide by the law and work with us to re-stabilize the damaged communities.”

http://www.housingwire.com/articles/33880-fannie-mae-accused-of-widespread-racial-discrimination

Editor’s Note: Discovery in an ongoing appraiser lawsuit against a bank and an AMC uncovers troubling evidence pointing to continued pressure on appraisers to “hit value.” (This story is taken from the new print edition of Working RE – in the mail now! Are you a Working RE Subscriber?)

Blacklisting Lawsuit Continues
by Isaac Peck, Associate Editor

In early 2014, North Carolina appraiser Michael J. McSwain filed a lawsuit against Yadkin Valley Bank and the appraisal management company (AMC) StreetLinks Lender Solutions, alleging that he was retaliated against for failing to reach targeted values. (See Smoking Gun Allows Appraiser to Sue Over Blacklisting)

According to the suit, McSwain performed two appraisals for StreetLinks in late 2012, on behalf of Yadkin Valley Bank, both of which failed to “meet value.” The suit cites explicit emails from the branch manager at Yadkin which state: “StreetLinks has sent out a BUTCHER on two of my last refis [sic] … make sure he is not sent out in our county and make sure he is not on the approval list…I thought I would let him do these two just to see. NOW THE DEALS ARE DEAD.”

Yadkin then demanded that StreetLinks remove McSwain from the bank’s Approved Appraiser List and according to new discovery documents that have been made public, McSwain was placed on Yadkin’s Exclusionary List in early 2013. McSwain then filed a lawsuit in February 2014 alleging that both Yadkin and StreetLinks engaged in unfair and deceptive business practices and were engaged in a civil conspiracy to encourage targeted appraisals.

The lawsuit remains ongoing but many of the facts that have come to light during the discovery process will be of interest to appraisers. More than any recent case, McSwain’s suit raises troubling questions regarding appraiser independence: namely, how much has changed since the Dodd-Frank reforms?

Appraiser Panels
At the heart of the issue is whether AMCs should create and maintain their own independent appraiser panels or allow lenders to handpick the appraisers they want used on their loans. In an interview with Working RE, Chuck Mureddu, managing director of AMC Quality Valuation Services (QVS), said that QVS uses its own panel. “We don’t believe in utilizing a lender’s panel because there’s a risk of diluting the independence part of building a fee panel,” said Mureddu.  (See Low Fee Solution: Cost Plus Model)

While independent appraiser panels are not specifically required under Dodd-Frank, many AMCs insist on them in order to safeguard appraiser independence. In fact, StreetLinks’ own Certificate of Compliance, that is issued with every appraisal and is signed by Steve Haslam, StreetLinks’ President and CEO, states that: “Appraiser Selection was performed at the sole discretion of StreetLinks by utilizing a selection methodology designed, maintained, and supervised by licensed real estate appraisers and is based on the criteria of proximity to the Subject Property, availability, and historical quality and performance metrics.”

However, in legal briefs filed as part of the discovery process, StreetLinks states that it “does not decide which appraisers are included on a lender’s exclusionary or preferred list,” writing that such moves are “solely the lender’s internal decision” and that StreetLinks “has no involvement in determining who belongs on the list, or why.”

Loan Production Staff
A central factor in McSwain’s lawsuit is the allegation that both Yadkin and StreetLinks violated appraiser independence by blacklisting McSwain for his failure to “meet value.” So far, Yadkin and StreetLinks deny any wrongdoing, insisting that their actions are completely legal.

The Appraiser Management Services Agreement between StreetLinks and Yadkin states “the lender panel will be delivered by Customer to StreetLinks…and MUST be sent by the Customer’s operations or compliance department directly from the Customer’s corporate office. StreetLinks will not be required to accept Lender Panel information from Customer’s production or sales staff.”

However, the initial suit filed by McSwain cites emails written by Yadkin’s Branch Manager, and a loan officer, which seem to indicate that direct input on the appraiser panel was made by the sales and production staff. The initial email that refers to McSwain as a “BUTCHER” and demands that he be removed from the approved list for “killing deals,” was sent by Yadkin’s Branch Manager, but it was a Mortgage Loan Assistant who ultimately contacted StreetLinks and instructed them to remove McSwain from the approved list. After confirmation that McSwain had been removed, Yadkin’s Branch Manager then forwarded the email chain to several other loan officers with the message: “FYI, I have had two cut deeply by appraiser,” according to the suit.

According to federal regulations, Yadkin is allowed to manage its own appraiser panel, but influence from sales and loan production staff is expressly forbidden. The Interagency Guidelines specifically address this point, stating that the “collateral valuation program is an integral component of the credit underwriting process and, therefore, should be isolated from influence by the institution’s loan production staff” and “the person who selects or oversees the selection of appraisers should be independent from the loan production area.”

Secret Blacklisting
McSwain’s experience is shared by many appraisers across the country who, without warning, suddenly stop receiving work from a client after a “low” appraisal is submitted. The internal emails from Yadkin provide a rare, behind-the-scenes record of what actually happens when a lender is unhappy enough with a missed value to retaliate against the appraiser.

In legal briefs filed as part of discovery, StreetLinks does not address the removal of McSwain from Yadkin’s approved list, but admits that McSwain was placed on Yadkin’s exclusionary list in January 2013 and that StreetLinks did not notify McSwain that he was placed on any exclusionary list. McSwain’s suit alleges that StreetLinks’ failure to notify him of his removal from “its list of qualified appraisers” is against both North Carolina AMC regulations, as well as rules adopted by the North Carolina Appraisal Board, which indicate that AMCs are prohibited from influencing a real estate appraisal by “allowing the removal of a real estate appraiser from a list of qualified appraisers used by any entity without prior written notice to the appraiser” (N.C. Gen. Stat. 93E-2-7 and 21 N.C. Admin Code 57D.0311a). In its discovery answers, StreetLinks expressly denies any obligation to notify appraisers that they are being placed on a lender’s exclusionary list and admits that StreetLinks “has not notified any appraiser that he/she was placed on a lender’s exclusionary list in North Carolina.

It also appears that Yadkin gave StreetLinks instructions to NOT place McSwain on the exclusionary list, but instead to simply remove him from the approved list. However, as part of the discovery process, StreetLinks actually submitted Yadkin’s exclusionary list and it appears that Michael McSwain is on the list.

Regulators Silent
The case remains ongoing in the Gaston County Superior Court and McSwain continues to seek damages from both Yadkin and StreetLinks. It remains to be seen if and when state and federal regulators will become involved in the case. Dodd-Frank defines a violation of appraiser independence as any instance where “A person with an interest in the underlying transaction…attempts to compensate, coerce, extort, collude, instruct, induce, bribe, or intimidate such a person, for the purpose of causing the appraised value assigned, under the appraisal, to the property to be based on any factor other than the independent judgment of the appraiser.”

StreetLinks’ discovery responses seem to provide supporting evidence for McSwain’s contention that he was placed on Yadkin’s Exclusionary List shortly after a Yadkin branch manager referred to him as a BUTCHER and blamed him for two failed deals. According to the suit, Yadkin did not review McSwain’s appraisals for errors or poor judgment and no complaint was ever filed against McSwain for bad appraisal work, nor was McSwain ever notified that he was being removed from an approved list or placed on an exclusionary list. Instead, Yadkin hired other appraisers who submitted appraisals that allowed the two deals to close.

Many appraisers see this case as a clear violation of appraiser independence but so far no state or federal regulators have shown interest in the case. Dodd-Frank mandates a penalty of up to $10,000 per day that the loan exists, so if this case is ever pursued by federal regulators, StreetLinks and Yadkin may each face fines in the millions, since the loans in question were funded in February and March of 2013.

Upcoming Live Webinars:
MAY: Bulletproof Appraising: Fannie Mae, Due Diligence and Your State Board – (Two-Part Webinar)
Presented by Tim Andersen, MAI
Part 1: May 12th, 10 – 11:30 a.m. PST
Part 2: May 19th, 10 – 11:30 a.m. PST

Are you prepared to successfully defend your work against inquiries from Fannie Mae, your state board and your AMC/lender clients? This webinar is designed to share an expert’s knowledge of what it takes to protect yourself. Gained through years of defending appraisers before their state boards, over real-life reporting issues, USPAP expert Tim Andersen, MAI helps you fill in any experience or knowledge gaps in your practice so you can appraise confidently and successfully. Learn More/ Sign Up Now!

JUNE: How to Support and Prove Your Adjustments – A Closer Look
Presented by Richard Hagar, SRA
Part 1: June 4th, 10 – 12:00 p.m. PST
Part 2: June 11th, 10 – 12:00 p.m. PST

“It was a great webinar, now I need to redo all my reports for the last 30 years!” – Sharon

Updated and expanded, Hagar shows you how to properly support your adjustments- the foundation of good appraising! Regulations state that appraisal adjustments cannot be based upon an appraiser’s opinion. Failure to provide proper proof and analysis to support your adjustments means a rough road ahead: state board complaints, panel removal, lawsuits, even license revocation. Fannie Mae cites “the use of adjustments that do not reflect market reaction” as the number one reason an appraiser can be “blacklisted.” This training is critical in helping appraisers avoid catastrophic appraisal failures. Learn More/ Sign Up Now!