FFIEC Requested Action on TRID
The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns:
As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers.
The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to be customary and reasonable. Current procedures for determing C&R fees are also ambiguous and subject to gross abuse.
TRID also incorporates non-appraiser third fees under the term “Appraiser Fees.” These are more properly described as lender and or third party appraisal management related administrative fees. Incorporating them as a single line disclosure item misleads consumers as to the true cost of real estate appraisals, and subjects them to added risk of inadequate service.
We urge that CFPB be directed to work with all national appraiser guilds, peer organizations and state coalitions in order to resolve these issues at the same time they are dealing with the other concerns cited in the original letter.
Respectfully Submitted
Peter Vidi, President
AGA, OPEIU/AFL-CIO
ABOUT THE AMERICAN GUILD OF APPRAISERS/OPEIU GUILD 44 – The American Guild of Appraisers/OPEIU Guild 44 seeks to represent the interests of appraisers, developing a strong presence before the U.S. Congress and each of the state legislatures. By working closely and exchanging dialog with other like-minded organizations, the AGA works to educate consumers about the appraisers’ non bias, independent role in the value process, while ensuring the accountability of both the appraisal profession and the financial institutions with which the appraiser provides services.
ABOUT OPEIU – The Office and Professional Employees International Union (OPEIU), AFL-CIO represents more than 104,000 members in the United States, Puerto Rico and Canada. OPEIU represents employees and independent contractors in banking and credit unions, insurance, higher education, shipping, hospitals, medical clinics, utilities, transportation, hotels, administrative offices and more.
Professional organizations and Guilds affiliated with OPEIU are a diverse group that includes nurses, pharmacists, chiropractors, appraisers, podiatrists, clinical social workers, minor league baseball umpires, teachers and helicopter pilots.
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Is it okay for me to copy this letter and send it under my signature to my representatives in Congress? I’m not sure it can hurt, but maybe it can help.
John, short answer, “Yes”, you may.
Though it may be better to write it as adding your signature to those of the Guild and other signors rather than as a solo signature. “Borrow” the strength of numbers from us and the others.
Along those lines, if you are not already a member, let me invite you to become one now. We can use ALL new members, but especially those willing to become actively involved by writing letters, posting to blogs and generally helping us to get our members issues out in front of as many legislators and regulators as is humanly possible.
Dues discount still applies right up to end of the year. Contact JanBellas@appraisersguild.org or call direct at 1(301) 220-4100 If cash flow & expense mineralization is an issue like it is for so many of us these days AGA can arrange for quarterly billing and invoicing. The main thing is that we could use people with the initiative you show in helping us take back our profession. Mike Ford, Dir. of Operations; Chairman Nat’l. Appraiser Peer Review Comm., AGA/OPEIU
Thanks Mike. I appreciate your response. I had your blog in the pile of things to read until I heard your podcast with Dustin on the Appraiser Coach. Then I printed it ASAP and looking to spread the gospel. Thanks again and I’ll contribute the most I can ass soon as I can
Sounds great John! I look forward to hearing from you in the future. Thank you for your current efforts.
this just in from Santa Claus.
Pretty well sums it up. I suppose I COULD become discouraged but then I think of what VaCap and AGA did together in Virginia and I get re energized.
Frankly with the combined support of individual state coalitions and AGA its ALMOST like shooting fish in a barrel.
Y’all ought to join! AGA http://www.appraisersguild.org