Certain states require that AMC employees be trained to ensure they understand assessment independence regulations as well as other legal requirements. Our free “Components of AMC Training” webinar will take place on June 10th at 2pm with Josh Walitt as host. This webinar will address certain key topics and give attendees an overall picture of what processes and issues are affected by rating independence, USPAP, discrimination laws and more. We sat down with the host, Josh Walitt, to discuss his upcoming webinar and what to expect from “Components of AMC Training” on June 10th at 2pm. Can’t make the time? Register to have the full record in your inbox as soon as it’s over!
to hum: Can we have your background in the industry?
Josh: I am a compliance and assessment consultant based in Colorado. I provide services to appraisers, banks, technology companies, education providers, valuation companies and lawyers. Depending on the client’s needs, my work includes coaching, tailor-made training, quality assurance, advanced training, disciplinary measures, internal auditing and other tailor-made projects. With appraisal clients, we typically focus on proactive practices, methodology and support, investigations, the use of assistants, workflow efficiency and technology.
To this point in my career, I have held a variety of positions including honorary assessor, 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 reviewers and other valuation professionals. I hold the SRA and AI-RRS designations at the Appraisal Institute, am a member of the National Association of Appraisers (MNAA) and serve on the national board, hold a Certificate as a Certified Distance Education Instructor (CDEI) and am AQB-certified USPAP Instructor and am an Appraisal Institute approved instructor. I was also chairman and co-chairman of the Agency Relations Committee of the Collateral Risk Network.
to hum: What is the focus of Walitt Solutions’ annual compliance training course?
Josh: The course is attended by employees of credit institutions and valuation companies and focuses on the need for companies to meet or exceed minimum training requirements from customers and regulators. Main topics include applying regulatory requirements and best practices in providing appraisals, contract management, reviewing reports, payments, interacting with appraisers and customers, understanding USPAP and investigating abuse and discrimination in relation to the appraisal process, appraisal independence, and appraisers .
to hum: Why do AMCs need the training?
Josh: The annual compliance training is designed to meet the requirements of customers and regulators. For example, certain states require that AMC employees be trained to ensure they understand assessment independence regulations as well as other legal requirements. In fact, some states have very specific content requirements for training. And of course, federal regulations and guidelines state that institutions and their agents must understand the appraisal management process to avoid violations. In addition, customer contracts often require review companies to ensure that employees receive appropriate training on various topics.
Businesses may not be sure that their own on-the-job training meets the needs of their customers and regulators. They are often more confident that they have issued a training certificate from a third party rather than realizing that their own training may not be effective or even meet the requirements. We continue to offer this training to AMCs and lenders, and have even customized it for multiple clients.
to hum: What are the tasks of an evaluation department?
Josh: Valuation departments, whether at a valuation management company or a lender, have many responsibilities related to the process of obtaining valuation reports that can be used for mortgage transactions. Employees must be familiar with the proper procedures related to reviewer requests, panel management processes (e.g. adding, removing), reviewer selection, reviewer remuneration, quality control of reports, mandatory reporting, requests for changes, complaints, and dealing with alleged or suspected Violations are familiar with the independence of assessment. Something as simple as handling a phone call incorrectly, specifying a fee incorrectly, or requesting a revision incorrectly can create problems and consequences.
In the end, as I often say in training, the assessment departments have to ensure that they employ qualified reviewers on the one hand and that they take a step back so that the reviewer can fulfill his function independently on the other. If both measures are not followed, you will have problems.
to hum: Will you address how an AMC deals with cancellation and reassignment of assignments, rating independence violations, and other communications with the appraiser?
Josh: Yes. The five hour annual compliance training covers many topics, including the ones you mentioned. The training gives employees a good awareness of many topics that they need to know about.
to hum: Which employees should be trained?
Josh: AMC and financial institution employees who employ appraisers, manage assignments, hire appraisers, request revisions, review reports, handle escalated problems or complaints, pay appraisers, or are a controlling person or manager should receive this type of training.
to hum: How are experts assigned to an order and according to which criteria?
Josh: Even before an expert is assigned to an order, expert management must meet certain minimum requirements in order to be part of the committee at all. Then, at the time of assignment, employees should consider factors such as previous performance, complexity, qualifications, type of eligibility, status, and other characteristics related to the assignment and the evaluator. We also cover how to deal with scenarios in which one party, e.g. B. a loan officer or a broker tries to select or deselect the appraiser.
to hum: How can revision requests be interpreted as a violation of assessment independence?
Josh: Often, alleged violations of valuation independence result from employees instructing the appraiser with regard to value, adjustments, comparative selection and property valuations. It is entirely acceptable for a review management department to question the reviewer’s process or report for further explanation or assistance. In general, however, employees should avoid instructing appraisers on these types of items. Participants exit the course with an understanding of the three categories that any revision request must fall into.
Since much of the interaction between reviewers and the appraisal management departments is related to revision requests, we spend a lot of time discussing scenarios during the course.
to hum: How should AMCs deal with a reassessment of value (ROV)?
Josh: If the AMC knows how to handle a revision request, it already knows how to handle a value check (ROV). This is because rechecking the value is just a certain type of request for revision. If you look at the regulations from a practical point of view, the value reviews are merely amendments that relate to the value. Regulations do not differentiate between a value-related change request and a non-value-related change request.
to hum: What USPAP considerations should an AMC always consider?
Josh: The course includes a general overview of the definitions, rules and standards, as well as other information related to USPAP, such as: B. Opinions. This approach gives participants a good understanding of the reviewers’ perspectives as they interact. For example, it is necessary to understand when a new assignment is being set up and what exactly that means for both the appraiser and the AMC if you want a successful, efficient and lawful relationship.
Remember, the course should not 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 a substitute for one another.
to hum: Does the course only focus on questions of assessment independence?
Josh: No, the course also focuses on other regulations that AMC customers expect them to train their staff on, such as UDAAP, ECOA, and Fair Housing. Given the concerns of customers and regulators about discrimination and fraudulent practices, it makes sense to dedicate part of the course to the relevant regulations. The course includes explanations of the regulations, high-level enforcement actions taken, and assessment-related scenarios.
to hum: How does the upcoming webinar compare to the actual four-hour training?
Josh: The 45-minute webinar will address certain key issues and give attendees an overall picture of what processes and issues are affected by assessment independence, USPAP and discrimination laws. The webinar also offers participants the opportunity to ask questions. You can register for the webinar here.
The full five-hour course provides training on the specific information, scenarios and topics required by customers and regulators. It’s a great opportunity for AMC and lender staff to learn and ask questions. Certificates of attendance (not CE) are issued so that companies can document the issues covered and keep track of employee training for audit records. For the entire course, you will find the options for registering for the classroom, live online and online delivery in self-study.
We’re excited that Josh took the time to answer our questions about his upcoming free “Components of AMC Training” webinar on June 10th at 2:00 pm.