AGA Objects De Minimis Increase Proposal

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Michael Ford

General Certified Real Estate Appraiser at Michael F. Ford Appraisal
Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory
Michael Ford

Latest posts by Michael Ford (see all)

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars

We object to the proposal to increase the de minimis threshold at which no appraisal is required…

Sirs:

The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters.

We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000 to $150,000 would be more prudent.

  1. The proposal is a job killer. There are roughly 85,000 licensed or certified appraisers in America today. This does not include new trainees that have been directed by their various state regulatory agencies (such as California) not to obtain any license until they are ready to actually take their tests for license of certification levels.  No one keeps track of these numbers as they used to do when trainees routinely applied for trainee or apprentice licenses and they could be enumerated. We are told this is for the benefit of the trainees, so that they are not subject to discipline during their training periods. That in itself makes no sense, but it is an aside to the issue of numbers.  Most of the 85,000 have spouses or partners increasing the directly affected people losing the benefits associated with hard work to over 170,000 excluding children and dependent extended family members.
  2. The proposal removes consumer protection. Home purchases are normally the largest single financial transaction decision consumers will make in their life time. This is no small thing. It is a decision that must not be entered into lightly. It is one that with prudent planning and consideration of all factors, may be the best financial blessing of their lives; or it can be the worst curse possible, driving them into complete financial ruin. Throughout the history of real estate and lending in the United States since the early 1930’s fraud, corruption, dishonesty, chicanery, forgery, theft of deposits & investor deception have been commonplace. Today is no different.

    • That is why we had Glass-Steagall (Banking Act of 1933)– to prevent a repeat of the Great Depression caused by dishonest banking practices.
    • The Lincoln Savings & Loan Crisis that lead to the S&L Bailout Bill (FIRREA 1989) was a prime example of the deliberate deception perpetrated by supposedly ‘Respectable, well run Lending Institution’, that in the end turned out to be a criminal operation. Fortunes were lost (and made by opportunists capitalizing on RTC ‘good deals’), to the detriment of taxpayers and depositors insurance fund.
    • The Financial Institutions Reform, Recovery & Enforcement Act of 1989 (FIRREA) was created to prevent this from ever happening again. Oddly, during its draft and revisions process it originally called for a de minimis threshold of only $25,000. Lenders; particularly those specializing in junior encumbrances (Second Mortgages) argued this was an unfair burden on borrowers ‘that clearly had more than enough equity for such little loans (though they never clarified HOW that was determined to be true), argued for a higher $50,000 de minimis. For reasons that are unclear to this day, The Congress; or more appropriately, those they had writing the legislation for them adopted a de minimis that was ten times higher than the original ‘safe’ proposal!  Please keep this in mind as you consider the spurious ‘inflation’ arguments for raising the limit.
    • As originally proposed, FIRREA envisioned appraisal field reviews of one in every ten appraisals performed as a means to assure the integrity, honesty and competency of those hired to perform collateral adequacy analyses. If that 10% field review criteria had been maintained it would have been virtually impossible for the Great Recession of 2008 and the Too big to Fail / TARP debacles to have taken place. Knowing their work would be reviewed for competency and accuracy would have prevented the 90% to 97% egregiously deficient appraisals that FDIC discovered performed on behalf of Countrywide and Washington Mutual in the early days of the recession. Meaningful quality control that cannot reasonably be circumvented could and would have completely prevented the disastrously under collateralized loans leading up to 2008. THIS WAS A 100% PREVENTABLE financial disaster, and fraud perpetrated on taxpayers and consumers. It was not limited to Countrywide or WAMU. Look at Wells Fargo’s track record of fines & admissions of guilt for outright fraud and deception over the past twenty years. These dishonest lender actions are not anomalies…they are the routine of business as usual! Let’s stop the pretense that we are dealing with honorable financial gurus only interested in ‘customer service’ rather than enhanced fleecing opportunities.
    • In the wake of the Countrywide / WAMU scandals, then NY Attorney General Andrew Cuomo blamed weak willed and immoral appraisers for the fraudulent appraisals. He adopted a settlement for New York to seek an alternative purportedly able to prevent this in the future by introducing what was later to become HVCC, or the Home Valuation Code of Conduct. Unfortunately he and other behind the scenes special interests selected the very same foxes that had been involved in facilitating so much loan fraud to operate as the gate keepers of appraiser independence and integrity. HVCC was one of the worst policies ever adopted by federally regulated institutions in a knee jerk reaction designed solely to be seen as “doing something” about the causes of TARP.
    • HVCC created a systematic scheme of appraisal price fixing across America (Read Coester VMS early advertising claims; or access any of the thousands of discovery documents in recent litigation against them by one courageous appraiser). Not only was HVCC responsible for price fixing, it encouraged and promoted a system in which completely unqualified, incompetent and often dishonest Appraisal Management Company executives routinely coerced inflated appraisals by threats and actual debarment from work against hundreds of appraisers.
    • Dodd-Frank was supposed to close up some of the loopholes created by HVCC that lingered even after HVCC was eliminated. The regulation was removed, but the results remained. Dodd Frank properly identified ongoing undue influence of appraisers as an issue requiring remediation. It also recognized that much like minimum wage laws, competent, professional quality appraisal expertise takes time, and requires adequate compensation. Absent either of these, appraisers unable to feed, clothe and house their families, or to care for their medical needs would once again be subject to undue financial pressures. The wording of the Act created admirable laws, regulations and goals…but failed to require or provide adequate enforcement measures. An inadequacy that remains to this day. The Reasonable & Customary appraiser fee requirement of Dodd-Frank has never been adequately enforced in the country.
    • Several states; most notably Louisiana; North Carolina, and Virginia took it upon themselves after much urging & warnings by appraisers, they passed defined and measurable ‘customary & reasonable fee laws’; and some passed AMC registration and licensing laws in advance of Appraisal Sub Committee requirements to do so.  Note how the term reversed from the Dodd Frank LAW to interpretation; “customary” somehow came before “reasonable” which is a much easier metric to define and measure. This was no accident. It was part of a plan and practice put into effect by AMC advocacy groups, that fully intended to circumvent the C&R fees by clouding how ‘customary’ would be interpreted. Even though Dodd Franks language already defined it. “Reasonable” ceased to be a meaningful consideration at all.
    • AMC Advocacy Groups acting on behalf of mortgage lenders, brokers and other lenders convinced the Federal Trade Commission (FTC) operating with less than a quorum of appointed Commissioners, to file suit against the one state that was attempting to enforce deliberate violations of their states C&R appraisal fee laws. That suit by FTC has resulted in virtually all other states that had minimum fee laws and requirements to cease enforcing them. It has been used as an excuse by others to defer passing enforcement or enabling legislation at state levels to implement the R&C (vs C&R) requirement of Dodd-Frank.
    • Dodd-Frank attacked by American Bankers. The consumer protection aspects of the Dodd-Frank legislation curtailed banks ability to defraud customers. It was attacked almost immediately by the bankers lobbyists and attorneys. Instead of being debated on its own merits as a law, it was turned into a political crusade of Blue Vs Red. The House Financial Services Committee under Congress Member Jeb Hensarling (R-TX) attempted to ‘repeal or replace’ it in its entirety, rather than only amend the potentially burdensome aspects of it that may be too severe on smaller banks (may or may not be). It would also have eliminated all the laws requiring appraiser independence and reasonable fees language.
    • Further erosion of consumer and appraiser rights and support through banking lobby manipulation. The TILA RESPA INTEGRATED DISCLOSURE (TRID) rule that became the new Truth in lending act / Real estate settlement procedures act FIXED APPRAISAL PRICES. The TRID is required to be given to a borrower at the time of the loan application. The quote for the appraisal fee is also given at that time. This is before an AMC is hired. This is before any appraiser or other competent person has screened the property to determine its appraisal / valuation complexity.

      The lender gives loan officers a fixed fee appraisal rate that they have agreed to accept and or split with the AMCs they contract with. The borrower appraisal fee quote (typically $650 to $725) is given before the AMC ever contacts an appraiser to obtain a  real quote. TRID can be revised if new signatures are obtained, but no (or exceptionally few) lenders have that level of integrity. Most falsely argue that once quoted, TRID can’t be revised at all. Therefore, a homeowner with a property that takes a $500; $1,000 or even $1,500 fee due to complexity is limited to bottom of the barrel appraisers that will accept $250 – $350 for the fee allowing the AMC and the bank to pocket the remaining $300 to $375! The settlement/escrow disclosure statement lies and misstates that the appraisal fee was $725 even though it wasn’t. The below C&R fee was as low as $250 in many instances. Behind the scenes state and federal regulations facilitate this fraudulent deception of taxpayer/consumer  borrowers.

    • Congress Member Maxine Waters (D-CA) is now the Chair of the powerful House Financial Services Committee. Congress Member Waters is not likely to overlook facilitation of further fraud by Administration officials or federal agencies. Bloomberg News recently reported: “Waters is a vocal Trump critic. As chair, she’ll have a powerful megaphone to call out misbehaving banks—and the investigative powers that come with it. Top priority: “To bring accountability to the Trump Administration and the regulatory agencies under the Committee’s jurisdiction,” including the Consumer Financial Protection Bureau, she said in a press release. Why Republicans should be scared: Expect Waters to be aggressive on oversight. That means more grilling of bank executives before the committee and more scrutiny of Trump’s relationships with financial institutions. This is not a good time for career bureaucrats of federal agencies to be adopting policies or rules that further erode consumer protections in such a public and obvious manner as increasing the de minimis limit does.
    • Make no mistake…Even though the AGA tries diligently to avoid partisan positions (after all appraisers are on both sides of the aisle, just like the rest of America is), we will not hesitate to hold the feet to the fire of any elected official; appointed bureaucrat, career civil service employee or regulator (by name) that facilitates further erosion of consumer and taxpayer protections for the benefit of proven thieves and swindlers.
  3. Unacceptable risk to taxpayers– Federal agencies have claimed with zero support for the claims, that increasing the threshold to $400,000 poses no increased risk to taxpayers. Of course it does! At minimum it increases the exposure to loss from $250,000 to $400,000! The only truth in the claim that increasing the limit ‘poses no more risk’ is within the context that so many, if not all protections have already been eroded so far that no “greater” risk results from yet one more stripped away protection. Taxpayers should not have to bail out Wall Street every 15 to 20 years!
  4. “Protect the Public Trust” is a phrase that appears throughout The Appraisal Foundation (TAF) publications and websites. It appears in the introductory language of virtually every states appraisal licensing and regulation laws. Their state implementing laws of FIRREA. Yet, it is never defined. Nearly every bad revision of USPAP; federal or state regulation that erodes public trust (as well as that held by appraisers themselves) recites the phrase “to protect the public trust” as justification for the evil intended change, revised interpretation or new administrative ‘process’…but none credibly define how the subsequent chicanery goes about doing that.
  5. False Flag, The reason most oft cited for increasing the de minimis threshold is ‘inflation’ from 1994 to present. (Oddly that same inflation is never accepted when reasonable appraisal fees are discussed). Adjustments for inflation are accepted as necessary for civil service employees; for Congress Members and state regulators. Inflation adjustments are appropriate for federal and state entitlement programs, where human beings depend on the income for living.
     
    Giving high risk activity a cute name  like de minimis threshold does not raise it to the level of an entitlement! In 1994 the de minimis was already TEN TIMES higher than the arguable safe-risk originally proposed amount! This was proven again in 2008 when FDIC discovered so many bad loans and appraisals associated with Countrywide HELOCS (Home Equity Lines of Credit). IF further consideration is to be given to raising the de minimis (instead of lowering it), then the federal agencies that have opined there is no increased risk need to cite specific studies performed by specific NAMED federal analysts that have proffered these opinions. We don’t recommend the thoroughly refuted FHFA white paper on AVMs to support the claim.
  6. It is time to call out the liars. The liars that claim consumers ‘demand’ faster mortgage processing. The liars that claim an “Amazon like” mortgage process that is faster and more intuitive is being demanded by consumers. The liars that claim big data and technology have all but eliminated the need for appraisals, while failing to acknowledge their own products still cannot reliably provide credible results on most properties analyzed. The liars whose stock cannot even be sold in America. The liars with a track record of deceiving American consumers and taxpayers going back before 1933. The liars that pretend receiving faster mortgage commissions isn’t a factor at all. The banking industry has not earned any degree of trust in over a hundred years.
     
    One claiming a history going back 150 years seems to spend every other year trying to reinvent itself so that consumers and investors will forget how they were all defrauded the year before. They are a necessary evil, but lets not pretend we have a moral obligation to treat their selfish special interests as an entitlement. Similarly, lets not let the ‘language of professionals’ hide the fact that many of the speakers are rogues of the worst sort. I’m ok calling proven liars ‘liars’. The FDIC should be too. Instead of considering a rise in the de minimis, referrals to the FTC for violation of the Sherman Anti Trust Act; and to the Department of Justice for an investigation into an ongoing criminal enterprise would be more appropriate under RICO statutes.
  7. I have been a real estate agent; credit union financial counselor, credit union manager and appraiser for well over forty years. I KNOW that consumers often second guess their hurried decisions. Even in normal term real estate sale transactions a real phenomena called buyers remorse crops up in nearly every sale & even refinances. We have it with impulse purchases. We have it buying cars. We absolutely have in in home purchases. It has to be dealt with. Usually through honest reassurance of the benefits, and checks and balances designed to protect the buyer or home owner. Increasingly though, subterfuge and a false illusion of speed being required is the chosen alternative. Afterall,, informed consumers are harder to defraud.

We, at AGA urge the FDIC and regulators to refuse to raise the threshold at which level appraisals may not be required in federally regulated institution transactions.

It’s for the protection and preservation of Public Trust.

Respectfully, for American Taxpayers and consumers,

Michael F. Ford, Vice President Special Projects
American Guild of Appraisers, #44 OPEIU, AFL-CIO
P.O. Box 553
Spencerville, MD 20868

(714) 366 9404

AppraisersBlogs urges anyone that has not already done so, to write. You may borrow, copy or quote anything from the above letter and add it to your own letters.
Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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40 Responses

  1. Kimberly Pugh DeFilippis on Facebook Kimberly Pugh DeFilippis on Facebook says:

    Take a few minutes and write a letter. Don’t fill out a form. Don’t send an email. WRITE A LETTER.

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  2. Chad Blackley on Facebook Chad Blackley on Facebook says:

    #3 should have been #1

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  3. Vincent R Simon on Facebook Vincent R Simon on Facebook says:

    Damn, you hit Trump on most of those points

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    • Mike Ford on Facebook Mike Ford on Facebook says:

      Vincent R Simon The odd thing is Im a Republican and generally conservative. My email was intended to convey facts. Both sides are needed to fix what both sides broke.

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  4. Baggins Baggins says:

    This article is a much appreciated history lesson. That’s a letter we can get behind and my letter will simply stand in support of yours, along with something unique like this could put me out of business, etc. Enhanced fleecing opportunities, we’ve been hoodwinked under the guise of automation! 

    Thank you for so clearly defining the problem and solution.

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  5. Avatar JW says:

    my comments have been submitted.

    Thanks for the link Mike

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  6. Avatar Diana N. says:

    Excellent letter Mike, count me as a supporter.

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  7. Dawn Aubrey on Facebook Dawn Aubrey on Facebook says:

    Please convey my respect and admiration to Mr. Ford on this fabulous article. I will be sending it to my Senators and Congresswoman.

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  8. Avatar Ron Maloney says:

    You should be commended Mike-thanks!

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  9. Avatar chris says:

    Wow, well said !!!

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  10. Avatar KD says:

    Mr. Ford, A true grit historical recap! I bow to you Sir and thank you for this well expressed “Truth”! Having been an appraiser for over 35 years, (I) we have lived the battle and hope The “Appraiser”… THE ONLY NOT BIASED “Licensed” PUBLIC Protection in the LENDING process…won’t die on the Hill !   

    I have for always thought the Public Borrower should be “ made aware ” that the appraiser DID NOT receive the Fee they thought they paid to the Lender; however, through (AMC) Service Contracts appraisers have never been able to “Inform The Public”. Since the AMC takeover which was due to “Lack of  GOV’ intervention”, the typical Appraiser is making less than ever & the Public “is not aware”. How can “the Public” even provide an Educated Comment, as per FDIC request? 

    Where FAKE NEWS says…”appraisals are TOO costly & take too LONG” please do the research to find the TRUTH where the Lender’s AMC keeps over half of the cost & where it can take EXTRA time to locate an Appraiser willing (OR by need of feeding family) must accept a Fee less than “Fair or Reasonable”.

    FIX: Require the AMC or THIRD Party to “NOT be able to retain more than what a Thorough Investigation in How to Survive in an AMC Run Appraisal World percentage” would be considered truly F&R (Fair & Reasonable). 

    Years ago there was to be a subcommittee investigation, did that ever happen? WHY has our Gov’ allowed the Public To Not Be Informed OR Protected? How can the public even BE Informed when there has never been ANY full disclosure?   

    Read Michael’s Article AGAIN! It is NOT FAKE News! Thank you  

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  11. Avatar KD says:

    Mr. Ford, A true grit historical recap! I bow to you Sir and thank you for this well expressed “Truth”! Having been an appraiser for over 35 years, (I) we have lived the battle and hope The “Appraiser” …THE ONLY NOT BIASED “Licensed” PUBLIC Protection in the LENDING process…won’t die on the Hill !   

    I have for always thought the Public Borrower should be “made aware” that the appraiser DID NOT receive the Fee they thought they paid to the Lender; however, through (AMC) Service Contracts appraisers have never been able to “Inform The Public”. Since the AMC takeover which was due to “Lack of  GOV’ intervention”, the typical Appraiser is making less than ever & the Public “is not aware”. How can “the Public” even provide an Educated Comment, as per FDIC request?

    Where FAKE NEWS says…”appraisals are TOO costly & take too LONG” please do the research to find the TRUTH where the Lender’s AMC keeps over half of the cost & where it can take EXTRA time to locate an Appraiser willing (OR by need of feeding family) must accept a Fee less than “Fair or Reasonable”.

    FIX: Require the AMC or THIRD Party to “NOT be able to retain more than what a Thorough Investigation in How to Survive in an AMC Run Appraisal World percentage” would be considered truly F&R (Fair & Reasonable).

    Years ago there was to be a subcommittee investigation, did that ever happen? WHY has our Gov’ allowed the Public To Not Be Informed OR Protected?  How can the public even BE Informed when there has never been ANY full disclosure?   
    Read Michael’s Article AGAIN! It is NOT FAKE News! Thank you  

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  12. Thank you Mr. Ford. There is a lot of information that the public needs to know and you summarized it very well!

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  13. Becky Lowell on Facebook Becky Lowell on Facebook says:

    Very well stated Mike Ford

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  14. Lynette Cook Jones on Facebook Lynette Cook Jones on Facebook says:

    Great analysis, Mike!

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  15. Gynell Vestal on Facebook Gynell Vestal on Facebook says:

    Very well said Mike. Thank you.

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  16. Avatar JW says:

    I am a proud member of the AGA and if you’re not this blog should tell you everything you need to know about why you should sign up today to become an AGA member

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  17. Avatar Teresa Martin says:

    Well written, Mike, thank you!

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  18. Mary Ann Momber Wright Mary Ann Momber Wright says:

    Thank you Mike Ford and AGA!

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  19. Avatar Wayne Courtney says:

    Mike is a good guy and he is working hard for all of us. I get up each morning and think how great it is to be retired. I almost took three assignments this week for vacant land with a 37% ownership. I quoted $1,800 for these and then found out that they were for a F** AMC. I turned them down. That was a trip to Hawaii and a lot of fun. However…I have said that I will NEVER work for a damn AMC. If you folks would join me…we could break their financial a**….but that will never happen. As a group “we” are going to let those bastards destroy our industry. But like I said, I have retired!

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    • I don’t think appraisers ever retire…we just slow down a bit. We should really talk about time costs for analyzing complex fractional ownership interests in real estate some time. As long as I don’t suggest that $4,500 would be my quote for the job you described – so we all should charge that much, we are ok with respect to Sherman Anti Trust. I would NEVER suggest such a thing.

      It’s interesting to hear what C&R fees are across the country. Makes it even more incredulous that banks think a national one size fits all TRID quoted appraisal fee could ever be anything other than price fixing. Thanks for reminding me.

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      • Avatar Wayne Courtney says:

        Gee Mike…we are talking about three tracts of rural acreage. I think about 30 acres, 20+/- acres and 7 acres. This assignment is like falling of a log….Would take me less than one day to wrap it up. $1,800. for one days work? I really wanted to jump on that but the FACT that a Gdamn AMC is involved….NOPE, NOT ME!

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        • Avatar Wayne Courtney says:

          Mike…I understand, it costs more to be in California than Texas…. You should have stopped by when you were in San Antonio….I would have bought you a beer! LOL

          Back in the 1980’s we had bumper stickers that said “WELCOME To TEXAS, now go home” LOL

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          • I dont blame you re stickers. Texas has always been a self help independent state. Beware of growing your urban areas too large or you will have numerically smaller, but concentrated voting blocks controlling the rest of the state. That’s how we lost it out here.

            Two of three cities can control the entire state (San Francisco; Los Angeles and San Diego).

            If I could convince my GF and daughter to move I’d do it in a heartbeat. Besides, my two brothers are located in San Antonio (one conservative and one liberal): I could upset the family balance of power!

            The downside, is you guys have to work too hard-non disclosure state. Catch ya next time on that ‘beer’ if we can make it ice tea.

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            • Avatar Wayne Courtney says:

              Ice tea is good….You are welcome but we do not need all of those ca folks here..Really TEXAS is just heaven on earth and really we are selective as to who can move in! LOL No shirt…this Texas thing is wonderful…we live the life of Riley…until the CA folks start scooting in! LOL….Can you tell that I like TEXAS?

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              • Avatar Wayne Courtney says:

                Mike…come join me…miles and miles of pine forests. lakes and more lakes…Opps…we are coming to a town…Pop> 202…then we are going thru more Pine forests and NO toll roads! Did I mention No dam traffic and no toll roads??? Come spend a few days with me! You will love it!

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  20. Avatar Tom Markoski says:

    Absolutely brilliant Mr.Ford. Well Done!

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  21. Avatar Wayne Courtney says:

    Mike…come join me…miles and miles of pine forests. lakes and more lakes…Opps…we are coming to a town…Pop> 202…then we are going thru more Pine forests and NO toll roads! Did I mention No dam traffic and no toll roads??? Come spend a few days with me! You will love it!

    Austin, San Antonio, Waco and all of that is just bumper to bumper city. Take a trip from Houston to Galveston. the city limit signs are back to back…TEXAS is exploding with People moving here….so many idiots from CA…Pardon…but in my area it is rural….I can be on a plane to Hawaii within about an hour…Or be at horse races or casino in an hour. I can fish for catfish or alligator…goats are next to my house begging for crackers….just a lot of fun here!

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  22. Avatar Wayne Courtney says:

    Mike…no kidding…bring GF and daughter and spend a few days with me. I can pick you up at SHV, GGG or Tyler… Heck the space shuttle landed at GGG…it is a back up airport for DFW…My home is not the palace but we could make it work…be like family! LOL…heck you will move here once you check it out! I will be on a cruise Feb. 3rd thru Feb 9th. and in Vicksburg, MS, on May 16 thru 19 or so.. I plan to go to Puebla, Mexico for a couple of weeks but have not picked the dates. Let me know if your schedule will work out?

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    • Avatar Wayne Courtney says:

      Do some google research for Caddo Lake…also Lake O’ the Pines, Martin Creek lake, Murval Lake, Toledo Bend, Lake Sam Rayburn and on and one…you can drown here! :LOL We have a lot of lakes, pine trees, Oil wells, gas wells, lignite coal..some poor folks like me and some that are as rich as six foot up a bulls ass…but that is just Texas! Little dinky airport in Marshall, TX with a population of about 24,000…airport can accomidate the lear jet? duh?

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    • Exceptionally generous and kind of you Wayne. I’d welcome the chance to meet you as well as see our AGA Rep Tony, his buddy Wade and a whole host of our TX AGA members in or near San Antonio.

      Maybe I can coordinate it with seeing my brothers, and their Mom. We’re fine with any of the hotels or motels in or near SA, but the guided tour sounds too good to pass up. Probably can’t break free though til June or July when my daughters out of school.

      NOW to figure out how to convince the GF…and that lack of degree thing (Thank you Mr. Brenan!). Wonder if I could recip and convert to permanent?

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  23. Baggins Baggins says:

    When is the last day for this letter again?  I’m like, putting it off but do intend on writing one.

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  24. Avatar Deborah says:

    Mike, While I was preparing my comments to be entered into the record on the $400,000 threshold under which an appraisal would not be required, I made a folder for study. I read your comments on that and the article on Freddie Mac, and I made a copy to take with me today. I went to a small town’s town hall meeting at a high school (Munroe, Oregon, north of Eugene) to participate and meet Senator Ron Wyden.

    I got a few things together and it was getting late so I’ll make my comments online later, but I wrote a personal memorandum expressing my opposition to the proposed change in de minimus, and attached your article on Freddie Mac because he is on the Finance Committee, and I wanted him to have some materials, and meet him. I did and spoke to him at the end of the meeting, and lobbied him to consider opposing this change in de minimus – I also said that we go through background checks, and protect the public trust like to software program can do, and we are needed but are being disrespected and destroyed by banks, and it has already eaten up a ton of Main Street families income for housing, so we need to do something with that. I live near where that guy brought a gun to school in Eugene the other day while involved in a custody dispute; the police were escorting him off campus and I think he pulled his gun – then they shot and killed him – right at the middle school down the street. I told him I am required to get background checked every year as I renew in alternating years my Oregon and California Appraiser’s License and that I shouldn’t be considered more dangerous than a guy who takes a gun to school. I am waiting for the investigation to decide what else could have been done.

    Anyway, wanted you to know your writings have been shared.

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    • Deborah, outstanding on the political contact. That’s how it all starts. Just keep in mind any one of us can toss that pebble in the pond and get the ripples started. Once something resonates with appraisers I can’t think of a more effective group of communicators and individual lobbyists.

      Keep in mind, Many Feds, from numerous agencies READ THIS BLOG!

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  25. Baggins Baggins says:

    Follow up. Links to read through comments later if you’re interested.

    https://www.regulations.gov/document?D=OCC_FRDOC_0001-0233

    Click open docket folder. Then click view all in comments.

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    • Avatar JW says:

      So appraisal waivers for everyone. Except in the event an appraisal is completed, those appraisals should be reviewed to make sure they comply with USPAP

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      • Worse than that. Real case: Yesterday a member calls to tell me he completed a “PDR” which appears to be some kind of field inspection only – no value. Distinct order and #. $150 fee. A week after completion lender AMROCK supposedly wants it ‘converted’ to a purchase appraisal (1004) for $400 BUT they will no longer pay for the inspection they ordered. Says appraiser would have had to do the same stuff he did in the PDR for the appraisal anyway. The appraisal is a separate order #.

        Separate type assignment altogether. There is nothing to ‘convert’ especially after delivery of a non-appraisal product.

        After thinking about it this seems a lot like the $149 PIW fees where the borrower is told NOT to get an appraisal until they see if the property qualifies for PIW; and if it doesn’t they (some lenders) are offered a full appraisal for “only” $149 more!

        Now these are different amounts than our member was cited but the idea is the same. NOW these bastards want appraisers to inspect a property so they can then go back and coerce them into doing a discounted appraisal! TWO different products and apparently one they believe it is ok to default on their obligation to pay!

        As soon as we can determine the type of loan that was involved we will file a complaint against AMROCK with their federal regulators as well as state (AMC) licensing board.

        In the meantime any appraiser that does the First American/ACI designed PDR reports is asking to get stiffed…not to mention undermining their own profession.

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AGA Objects De Minimis Increase Proposal

by Michael Ford time to read: 11 min