Commercial And Multifamily Mortgage Delinquencies Remain Low

Commercial and multifamily mortgage delinquencies stayed low in the first quarter of 2019, according to the Mortgage Bankers Association’s (MBA) latest Commercial/Multifamily Delinquency Report.

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“Steady U.S. economic growth continues to support the financing and values of commercial and multifamily properties,” said Jamie Woodwell, MBA’s Vice President of Commercial Research & Economics. “Commercial/multifamily mortgage delinquencies remain at or near record lows for most capital sources, and it’s hard to imagine loans performing better than they currently do. Given the environment, there’s little reason to expect a marked deterioration of near-term performance.”

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MBA’s quarterly analysis looks at commercial/multifamily delinquency rates for five of the largest investor-groups: commercial banks and thrifts, commercial mortgage-backed securities (CMBS), life insurance companies, Fannie Mae and Freddie Mac. Together, these groups hold more than 80 percent of the commercial/multifamily mortgage debt outstanding.

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Based on the unpaid principal balance (UPB) of loans, delinquency rates for each group at the end of the first quarter were as follows:

  • Banks and thrifts (90 or more days delinquent or in non-accrual): 0.48 percent, unchanged from the fourth quarter of 2018;
  • Life company portfolios (60 or more days delinquent): 0.04 percent, a decrease of 0.01 percentage points from the fourth quarter of 2018;
  • Fannie Mae (60 or more days delinquent): 0.07 percent, an increase of 0.01 percentage points from the fourth quarter of 2018;
  • Freddie Mac (60 or more days delinquent): 0.03 percent, an increase of 0.02 percentage points from the fourth quarter of 2018; and
  • CMBS (30 or more days delinquent or in REO): 2.61 percent, a decrease of 0.16 percentage points from the fourth quarter of 2018.

MBA’s analysis incorporates the measures used by each individual investor group to track the performance of their loans. Because each investor group tracks delinquencies in its own way, delinquency rates are not comparable from one group to another.

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Construction and development loans are generally not included in the numbers presented in MBA’s report, but are included in many regulatory definitions of ‘commercial real estate,’ despite the fact they are often backed by single-family residential development projects rather than by office buildings, apartment buildings, shopping centers, or other income-producing properties. The FDIC delinquency rates for bank and thrift held mortgages reported here do include loans backed by owner-occupied commercial properties

Commercial/Multifamily Originations Increase 12 Percent In The First Quarter

Commercial and multifamily mortgage loan originations rose 12 percent in the first quarter compared to the same period last year , according to the Mortgage Bankers Association’s (MBA) Quarterly Survey of Commercial/Multifamily Mortgage Bankers Originations. In line with seasonality trends, originations the first three months of the year were 34 percent lower than the fourth quarter of 2018.

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“The momentum seen in 2018’s record year of borrowing and lending continued in the first quarter of this year,” said Jamie Woodwell, MBA’s Vice President of Commercial Real Estate Research. “First quarter volumes were higher for nearly every property type, and double-digit growth in loan volume for Fannie Mae and Freddie Mac led the increase among capital sources. Low interest rates and strong property values continue to make commercial real estate an attractive market for borrowers.”

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Compared to a year earlier, a rise in originations for industrial, health care and hotel properties led the overall increase in commercial/multifamily lending volumes. By property type, industrial (73 percent), health care (41 percent), hotels (14 percent), retail (9 percent) and multifamily (9 percent) all saw year-over-year gains by dollar volume. The dollar volume of office property loans was unchanged.

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Among investor types, the dollar volume of loans originated for Government Sponsored Enterprises (GSEs – Fannie Mae and Freddie Mac) increased by 14 percent year-over-year. Life insurance company loans increased 7 percent, commercial bank portfolios increased 6 percent, while loans originated for Commercial Mortgage Backed Securities (CMBS) decreased 4 percent. 

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As is typical in the first quarter, originations decreased in comparison to last year’s fourth quarter, with total activity falling 34 percent. Among property types, declines were seen in health care (49 percent), hotels (45 percent), multifamily (40 percent), retail (32 percent) and office space (30 percent). Industrial properties bucked the overall trend, rising 17 percent from the fourth quarter of 2018.

Among investor types, the dollar volume of loans for GSEs decreased 43 percent, originations for commercial banks decreased 34 percent, loans for life insurance companies decreased by 28 percent, and loans for CMBS decreased 22 percent.

To view the full report of MBA’s Quarterly Survey of Commercial/Multifamily Mortgage Bankers Originations, please visit:

2018 Ends On A High Note With A 14% Rise In Commercial/Multifamily Borrowing

A strong final three months of the year helped commercial and multifamily mortgage originations increase by three percent in 2018, according to preliminary estimates from the Mortgage Bankers Association’s (MBA) Quarterly Survey of Commercial/Multifamily Mortgage Bankers Originations, released here today at the 2019 Commercial Real Estate Finance/Multifamily Housing Convention & Expo.

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“2018 ended on a strong note for commercial mortgage borrowing and lending, with fourth quarter originations 14 percent higher than a year earlier, despite the broader market volatility,” said Jamie Woodwell, MBA’s Vice President for Commercial Real Estate Research. “Investor and lender interest in multifamily and industrial properties continues to drive transaction volumes while questions about retail and office property markets have slowed activity for those property types. The market as a whole ended the year roughly flat compared to 2017, continuing a plateau we’ve seen in mortgage borrowing and lending since 2015.”


An increase in fourth quarter originations for healthcare, multifamily and industrial properties led the overall increase in commercial/multifamily lending volumes in the fourth quarter compared to the same quarter in 2017. The fourth quarter saw a 61 percent year-over-year increase in the dollar volume of loans for healthcare properties, a 32 percent increase for multifamily properties, a 28 percent increase for industrial properties, and a slight increase (one percent) for retail properties. Originations decreased for hotel property loans (4 percent) and office property loans (3 percent).  

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Among investor types, the dollar volume of loans originated for the Government Sponsored Enterprises (GSEs – Fannie Mae and Freddie Mac) increased year-over-year by 32 percent. There was a 22 percent increase for life insurance company loans and a five percent increase in commercial bank portfolio loans. The dollar volume of loans for Commercial Mortgage Backed Securities (CMBS) declined 35 percent.


Compared to 2018’s third quarter, fourth quarter originations for health care properties jumped 155 percent. There was a 56 percent increase in originations for hotel properties, a 34 percent increase for industrial properties, a 30 percent increase for multifamily properties, a 29 percent increase for office properties, and an 11 percent increase for retail properties compared to the third quarter of 2018.

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Among investor types, between the third and fourth quarter of 2018, the dollar volume of loans for commercial bank portfolios increased 46 percent, loans for the GSEs increased 32 percent, originations for CMBS increased 31 percent, and loans for life insurance companies increased by 30 percent.


A preliminary measure of commercial and multifamily mortgage origination volumes shows that 2018 originations were three percent higher than 2017. By property type, originations for multifamily properties increased 22 percent, originations for industrial properties rose 12 percent, and originations climbed 5 percent for hotel properties. Office property originations were down 7 percent, retail properties declined 13 percent and healthcare properties decreased a 16 percent.

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Among investor types, loans for the GSEs increased 16 percent between 2017 and 2018 and originations for life insurance companies increased 10 percent. Loans for commercial bank portfolios decreased 10 percent and loans for CMBS decreased 26 percent.

In late March, MBA will release its Annual Origination Summation report for 2018, with final origination figures for the year.

Next-Generation Valuation Management Software Platform For Commercial Lending Launches

Global DMS launched EVO-Commercial (EVO-C). The new platform is 100 percent configurable, fully customizable, quick and easy to implement, eliminates numerous steps in the workflow process, lowers system maintenance costs and empowers end-users as well as management teams, among many other efficiency gains.

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“EVO-C solves a number of major pain points and challenges that have been ailing the commercial lending space for years,” says said Vladimir Bien-Aime, president and CEO at Global DMS. “Commercial lenders have grown accustomed to dealing with manual processes or limitations of outdated, inflexible technology that prevents them from optimizing their valuation processes. The feedback we have received from commercial lenders thus far is that EVO-C eclipses and outperforms the current solutions which they are continually burdened with.”

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The EVO-C platform delivers immediate ROI to lender clients by reducing the cost to acquire, manage and review collateral valuations reports. The solution creates a competitive bidding environment where vendors are encouraged to focus on quality, communication, cost and turnaround time. Managers are easily able to monitor their pipelines in real-time for overall performance to drive down costs, remove road-blocks and create a positive experience for their customers.

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Key EVO-C Benefits:

>>Implementations can be completed in just days or weeks – not months

>>EVO-C is so intuitive and easy to understand that minimal training is required

>>Completely workflow-driven powered by a highly configurable business rules engine that does not require development or IT resources to update

>>Detailed custom reports can easily be created by business users and dynamically output on an ad hoc basis for management

>>Drag and drop capability allows for multiple large files to swiftly be transferred and auto-populated, saving immeasurable amounts of time

“We spent a great deal of time working closely with lenders to perfect a breakthrough platform that is loaded with features and functionality, which commercial lenders have never seen before,” said Michael Quaranto, chief information security officer and vice president of technology at Global DMS. “EVO-C was engineered to be hands down the most flexible, configurable and extensible commercial lending valuation management platform available on the market. We are extremely excited to demonstrate the jaw-dropping power EVO-C offers.”

Global DMS is an established enterprise-class software provider that also offers a widely-used, residential lending valuation management platform, eTrac, which seamlessly automates all aspects of the process. eTrac supports lender compliance with changing state-based rules, federal laws, the Consumer Financial Protection Bureau (CFPB) and the Dodd-Frank Act.

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Give Commercial Lending A Try

Extensia Financial, one of the nation’s largest Credit Union Service Organization (CUSO) dedicated to commercial real estate lending and advisory services, announced that it offers commercial real estate lending consultative services to help credit unions develop and/or maintain successful commercial lending programs.

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Extensia’s consultative services are designed to help credit unions interested in beginning an in-house commercial lending program understand best practices and potential risks. Extensia also helps credit unions with established commercial real estate lending programs analyze their risk, make necessary adjustments to underwriting practices and handle complex note sales.

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Extensia offers this service alongside its annual loan review consultative services and its comprehensive commercial real estate lending program, which can handle credit union commercial lending from funding to servicing. As the industry is adjusting to the upcoming changes to the NCUA’s MBL guidance taking effect in January 2017, Extensia serves as a resource to credit unions interested in diversifying their loan portfolios through commercial lending programs.

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“Our comprehensive consultative services are an educational program designed to help credit unions build a sustainable commercial lending program that fully supports their strategy and roadmap,” said Pam Easley, CEO of Extensia Financial. “We also work extensively with credit unions that have established programs to develop more sophisticated risk-management procedures, such as updating underwriting practices for the highest quality loans.”

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Making Commercial Lending Easier

CU Companies continues to diversify its product offerings with the launch of a new commercial closing service available nationwide. CU Commercial Title Services will provide commercial title services, construction disbursing, and escrow services to brokerage groups, lending institutions, attorneys, businesses, and individuals.

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Melissa K. Page Boeshans joins the CU Companies team as the new President of CU Commercial Title Services. Boeshans comes with an extensive background in commercial closing and a strong devotion toward building and maintaining customer relationships. With over 20 years of title experience and a background in law, she brings the capability to immediately serve clients.

“I am thrilled for this new opportunity to use my skill set and pave the way for CU Companies’ commercial closing services,” said Boeshans. “The growth CU Companies has made over the past few years has set them up perfectly for success in the commercial title industry. Having the opportunity to use my experience to provide additional resources for clients and help expand the products and services the company offers is very exciting.”

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Boeshans’ focus is to deliver her expertise to the commercial closing process while adding a level of sophistication. For her, that means serving as a trusted resource for clients in a way that goes beyond the basics and serves in a consultative manner as it relates to all-encompassing title concerns. It also includes helping clients through unpredictable issues that can arise. “I take that solutions-based mentality very seriously and it’s the difference necessary to maintain loyal clients; it’s an expectation I set and always deliver,” Boeshans added.

Some Nonbank Servicers Advance As Bankers Retreat

As commercial banks and thrifts continue to move away from the mortgage subservicing business, some, including Inside Mortgage Finance reporter John Bancroft, are wondering whether nonbanks are “strong enough to pick up the slack.” Bancroft posed the question in a story last week. IMF reported that depositories serviced $4.054 trillion in single family mortgages at the end of last year, down 2.04% from the third quarter of last year. RoundPoint Mortgage Servicing Chairman and CEO Kevin Brungardt offers an answer to that question: send the business to us.

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“The fear on the part of many, and it’s well founded, is that many of the nonbank servicers pursued growth before they had built a compliance infrastructure that would allow them to operate in the Dodd-Frank world,” Brungardt said. “RoundPoint did not make that mistake. We have a stable, compliant platform that will allow for our growth. As the banks move away from this business, as they should given the high cost of their compliance overhead, we are happy to step in and take it.”

In his story, Bancroft pointed out that banks have been retreating from the servicing business since 2009, when their combined portfolio was close to $6 trillion. That’s now down to less than one-third of that number. Unfortunately, the nonbank servicers that rushed in to scoop up much of that business did so prematurely, before they had the compliance infrastructure in place to handle it. Focusing on growth before they had built fully compliant operating platforms was the critical mistake virtually every nonbank servicer made coming out of the foreclosure crisis.

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“We didn’t put the cart before the horse,” Brungardt said. “That sets us apart now and makes it possible for us to grow without the risk that many of our peers now face.”

RoundPoint is a fully-licensed Agency and Non-Agency subservicer for commercial banks, credit unions, mortgage companies and hedge funds. RoundPoint currently services over $50 billion worth of mortgage assets, some of which it owns but the majority of which is subservices for loan originations nationwide. The firm provides a superior suite of end-to-end services, including loan boarding, escrow administration, cashiering, investor reporting, member services, and default management. Its leadership team works directly with investors to design a customized servicing approach that provides the best possible outcomes for borrowers.

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Commercial Lending Resurgence


Ashish Deshmukh - Photokaushal_Verma (Newgen)Commercial Lending in the United States has been a roller-coaster ride over the past few years. It remained the most profitable business arm for banks till 2008, when the financial crisis came along as a huge reality check. The global meltdown brought with itself sweeping changes that transformed the operational and strategic framework of this critical financial instrument forever.

The focus on the customer and the top-line growth clearly got sidelined, while a wave of skepticism seeped in, pervading all through. This skepticism was characterized by the prioritization of risk management and compliance measures over customer experience and operational responsiveness. The processes became rigid and strenuous as the internal business policies got aligned with the tight external market conditions. An air of sheer conservatism gripped the commercial lending market, from Corporate and Industrial Lending to Commercial Real Estate, Equipment Financing, and Consumer and Small Business Lending.

Recently, however there are clear signs of revival as the international markets have consolidated and diversified. In a sign of increased confidence, large, small and foreign-related banks in the United States increased commercial and industrial loans at double-digit rates in the last year. Loans to commercial and industrial firms rose 8.5% in the first quarter of 2015 and is all set to outpace residential mortgages soon according to the data released by Federal Deposit Insurance Corp. Commercial Lending has also gained ground within the “smaller” domestically chartered banks.

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This is one of the best showings in a long time.

However, there is an all new set of challenges that awaits them as they gear up for this battle to remain competitive and compliant.

>> Regulatory oversight has intensified significantly, and managing new and evolving requirements is a challenge – particularly from the perspective of accurate reporting requirements of Dodd Frank and CECL

>> Risk management is becoming a holistic process across lending institutions, requiring more standardized processes and better understanding of exceptions

>> Aggressive competition from other banks and emerging non-banking lenders is a threat

>> New and upcoming sectors are providing opportunities with immense potential that cannot be neglected

Business Transformation – The Need of the Hour

The recent turn of events augur well for banks and financial institutions globally. They also create a compelling need to steer away from the shadows of 2008, and rope in incremental changes that deliver a competitive advantage to banks early on in the rapidly stabilizing economic environment. Slowly by surely, most forward looking banks have shed the self-imposed ‘cocoon’ that implied limited target markets and lack of process innovations. They are now moving towards modernizing the commercial loan origination function by relying on proven technologies and trusted domain experts to transform their businesses. By doing so, they aim at achieving a balance between the need to reduce operating costs and risk with the need to win more customers and expand profitable relationships.

Drivers Expectations
Revenues •       Sell more loans with increased sales capacity

•       Unified view of the customer relationship

•       Improved turnaround times

•       Better customer experience

Efficiency •       Optimize FTEs needed

•       Operational efficiency and resource productivity

•       Automated Credit Risk Assessment

•       Guaranteed timelines on credit approvals

Expenses •       Reduce IT Hardware and maintenance costs

•       Reduce Third-party integration costs

Risk •       Reduction in regulatory and compliance fines

•       Improved employee retention rates

•       Real-time pipeline

•       Consistent portfolio management

•       Automatic covenant monitoring and collateral management

Maintenance •       Implement changes to the system and become self-reliant to provide new capabilities.

Multiple stakeholders involved in the commercial lending lifecycle have distinct set of expectations from such transformation.

The Three Choices

Banks may adopt one of the three technology choices to meet the above imperatives.

The Traditional Approach – Building an Enterprise Application

Large Banks can leverage hard coded enterprise applications or systems to manage the policies, processes and structures within the commercial lending process. They have to develop an in-house application by setting up a team and corresponding infrastructure. These monolithic applications are hardcoded and do not support process level changes associated with the evolving market dynamics and regulatory compliances. Moreover, These solutions provide automation only in certain aspects of the process and not end-to-end automation. Any change introduced at a later stage can be a costly and time consuming affair, prolonging the time to market and compromising the business and operational agility.

The Point Solution Approach

A point solution would possibly address the current needs of the bank with regards to the automation of the commercial lending process. However, it will not allow the bank to introduce incremental improvements by limiting the flexibility of process changes due to its rigid solution architecture. Also, with disparate systems to work with, employees will not be able to function at the productivity levels that they are capable of.

The Transformative Approach – BPM Based Solutions

The pervading technology which bears the capability of an end-to-end transformation of commercial lending processes is a framework based approach called Business Process Management (BPM). It has the inherent benefits of both “build” & “buying of the shelf” along with the adaptability to business stakeholders to drive the solution based on their business strategy & regulatory compliance level changes.

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The BPM platforms consist of configurable components like the rules engine (BRMS) to store the credit policies, Document Management System (DMS) and workflow which enable businesses to run processes they want rather than what the application demands. Customizable user interface, seamless integration with third party software & mobility framework further enhance the productivity levels

Whether it is the question of increasing profitability, ensuring business agility, reducing business risks or enhancing customer experience and satisfaction, BPM can deliver by focusing on continuous process improvement and operational flexibility. It helps banks meet both its short and long-term objectives.


BPM facilitates collaboration between business and IT providing the bank with levers to implement a future ready solution, which enables:

>> Automating the lending approval process and implementing an optimized workflow, that enables improved TAT, predictability, transparency and better decision-making

>> Segregating tasks to enable the RM to focus on sales and passing non-value add data entry activities to back office / operations teams

>> Building a wrapper layer over all existing loan systems to give stakeholders access to all relevant information centrally

>> Digitizing the proposal to online forms. This facilitates capturing information in an actionable format and reproducing it in a Word / PDF document in the bank’s defined format for user reference

A BPM based integrated platform supports the entire credit lifecycle as well as exploit new delivery channels. This improves the efficiency and performance of all lending business units, which ultimately increases customer satisfaction across the entire credit lifecycle.

5 Things to Consider while Implementing a BPM Platform

What banks should be looking for during BPM selection and implementation, is recommended to be based on the following criteria:

1.) Power in the Hands of Business – The ability to change and modify processes according to the market needs and business strategy is a vital cog in the wheel. Banks must look for platform based solutions that offer this agility within their core framework, without the need for massive IT driven customizations.

2.) Business Impact Analysis – Banks must roll out the enterprise wide process transformation in a smooth manner, leveraging the existing infrastructure as much as possible. The training and complexity involved in the rollout must never go overboard or overwhelming for the business.

3.) Quick Time to Market New Products – Implementing a BPM platform is not just an IT infrastructural change. It must transcend both business and technology to align the organizational processes with the market dynamics. Simply put, it must support quick transitions in product and service offerings

4.) Enterprise Level Collaboration: BPM framework must have the capabilities which facilitate distinct business units (LOB’s) and systems to talk/interface to multiple underlying applications seamlessly. This interoperability is critical for creating efficiencies across key decision making scenarios. Integration with third party credit agencies & core solutions (jack henry ,Flexcube, Moody’s etc.) must be a salient feature of the project

5.) Unified View of Group Level Risk Exposure – The BPM platform must provide a holistic set of analytical tools at every stage of the process to assess the risk associated. Real-time process monitoring along with model driven risk assessment systems can enable this key business need.

The current positive sentiment of the market complimented by rampant industrial growth across most sectors clearly indicate the need to take bold steps. Banks and financial institutions must not shy away from the imminent need to adopt advanced IT systems that support business innovation. With BPM driven agility and process visibility, the fear of the unknown perishes, allowing organizations to undertake this transformation head on.

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Mobile And Commercial Mortgages

*Mobile And Commercial Mortgages*
**By Tony Garritano**

TonyG***It has been a while since I last shared news about mobile technology penetrating the mortgage space. I recently learned of an interesting use of this technology in the commercial mortgage space. In this case, Real Integrated Technology, LLC has entered into a relationship and begun early adoption testing of its Commercial Site Inspector, (CSI), a mobile site inspection platform, with StanCorp Mortgage Investors, LLC (SMI). The ability to reduce the time it takes to perform a commercial property inspection, improve accuracy, and connect to its servicing system led the company to opt to proceed with additional field testing of CSI.

****SMI is a subsidiary of StanCorp Financial Group, Inc., a provider of financial products and services. SMI has a loan portfolio that includes approximately 6,500 loans, valued at $8.3 billion as of June 30, 2013. SMI currently sources and services the vast majority of their loans through an independent correspondent network.

****“We are very pleased that SMI has recognized the benefits of CSI and has decided to test the platform, evaluate its performance, and experience first hand the advantages it delivers to users,” said Mark Chrisman, CEO of Real Integrated Technology. “The result is that the firm will be able to quantify for itself the efficiency gains our inspection platform provides to the company and the industry.”

****“I am excited about the potential of the new technology which incorporates the efficiencies gained during the inspection by using the iPad, and the ability to directly and easily integrate the data into our servicing platform,” said Gregg Harrod, AVP, Operations at SMI.

****Consultants use CSI because it reduces the time that inspections require while improving their performance. “As an inspector, receiving and completing inspections on the iPad has greatly improved my efficiency by eliminating the need to return to my computer to capture my notes and pictures,” said Matthew Fisher, CEO and Chief Inspection Officer at California Property Inspection.

Market Analysis: Making The Life Of The Appraiser Better

*Making The Life Of The Appraiser Better*
**By Tony Garritano**

***The Interagency Appraisal and Evaluation Guidelines, issued in December of 2010, provide specific standards for evaluations. While those guidelines do not require that a licensed appraiser prepare an evaluation, they do expressly permit a licensed appraiser to prepare an evaluation. However, many appraisers have expressed concern that preparing an evaluation may violate the Uniform Standards of Professional Appraisal Practice (USPAP), the appraisal standards by which most states require all licensed appraisers to comply, especially because of so-called scope of work rules and the fact that the reporting requirements of USPAP require an appraiser to use one of only three recognized appraisal reporting forms. But USPAP provides the flexibility appraisers need to prepare an evaluation. As a result, MountainSeed Appraisal Management, LLC, a full-service residential and commercial appraisal-management firm, has launched a new program that makes it easier for licensed and certified appraisers to offer commercial evaluations to community and regional lenders.

****Real-estate evaluations are valuations of real property prepared in connection with typically low-risk transactions that qualify for one of three specific appraisal exemptions provided in the federal bank regulators’ appraisal regulations. “Because we work so closely with the appraisal community we always scratched our head at why appraisers, who were most qualified to do an evaluation, were not getting these assignments,” said Carl Streck, CEO of MountainSeed Appraisal Management, LLC. “Over the past few months we have worked with the lending and appraisal communities to resolve the communication breakdown and develop a program to offer evaluation assignments to appraisers.”

****MountainSeed will be presenting a complimentary one-hour webinar on Thursday, July 12 at 2:00 p.m., Eastern, to provide the basics of commercial evaluations and describe the new appraiser evaluation program. Information on the webinar and registration are found at

****The program gives banks, who may have been forced to rely on less-skilled employees or analysts, the ability to draw on the deep expertise of the appraisal community. The program educates appraisers on how to perform what a bank calls an evaluation in an appraisal format. MountainSeed will also be educating commercial lenders on the product.

****“The beauty of our new product is it exemplifies our continuing commitment to the appraiser community by finding ways to get them work that they didn’t have before,” Streck said. “It also gives our clients the ability to order an evaluation in markets like Pennsylvania, South Carolina, Michigan, Florida, Connecticut and others where state-law licensing issues may prevent or make it difficult for unlicensed persons to perform them.”