Category: Appraisal Management Companies

Question your appraisal fees 5

How Much Do You Charge for a 1004?

Question: “Care to reveal the minimum fee for a ‘typical’ 1004 + MC in your area?” Had an interesting email come in yesterday. It came from a friend of mine in the appraisal industry and began with this question, “Care to reveal the minimum fee for a ‘typical’ 1004 + MC in your area?” The message went on to express some concern over some of the shenanigans that was going on in his own area concerning AMCs, low fees, and appraiser’s willingness to sell themselves short. Unfortunately, the same is likely going on in every community (yours included). Though the...

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Sense is like courtesy it is no longer common!

I dealt with an old question recently that I felt was pertinent and worthy of repeating. The question arose in Brooklyn, NY when an underwriter demanded that the appraiser include the basement area as part of the gross building area when comparing the subject to the comparable sales. After all they reasoned, Fannie Mae guidelines, i.e. Property and Appraisal Guidelines, XI 405.07 state, “Gross building area, which is the total finished area (including any interior common areas, such as stairways and hallways) of the improvements based on exterior measurements, is the most common comparison for two-to four-family properties. The gross...

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Memorandum to Kentucky Registered AMCs Regarding Appraiser Independence, Objectivity, and Impartiality

From: Larry Disney, To: Kentucky Registered Appraisal Management Companies and Credentialed Appraisers, Date: March 29, 2012 Subject: Appraiser Independence, Objectivity, and Impartiality The Kentucky Real Estate Appraisers Board staff has received calls from Kentucky credentialed appraisers in the past two weeks concerning the following issue that is being propagated by Appraisal Management Companies: When appraising one unit residential properties and reporting the results of the appraisal development using a 1004 Fannie Mae form, the appraisers are told that if the cost approach is developed and reported, regardless of reasoning, the appraiser shall not consider the opinion of value developed via...

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We Need More Regulations?

“There oughtta be a law!” This is the typical rant from well-meaning Americans who feel they have been wronged in some way. In some cases, they may be right. There is a place for government and there are a reasons for regulations. The problems is, we have too dang many of them! Appraisers of any walk are usually the first ones to complain against excess government overreach. Yet surprisingly, they can also be the first ones to call for more when it appears to be in their favor. Take a recent thread I was reading on a popular appraiser web...

Top to Bottom Complaint Primer 0

Top to Bottom: Complaint Primer

“Why don’t you write about the complaint process from start to finish?” Howard Richter, MAI of IACREA made a great suggestion for an article. “Why don’t you write about the complaint process from start to finish?” Okay, Howard. Let’s do it! Whether complaints come from homeowners, lenders, AMCs, other government entities, they all find their way to my desk via Complaint Intake. The two-page complaint form is on-line and was designed to make it easy for the complainant and for the Department to get to the heart of the problem. Complaints come in all shapes and sizes. Some are vague...

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Questions & Comments RE Customary and Reasonable Fees

Where To Direct Questions and Comments Regarding Customary and Reasonable Fees The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB...

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The 8 Biggest Appraiser Liability Cases in the U.S.

I have described below the 8 biggest appraiser liability cases with which I am familiar that are currently pending in the U.S. These are cases that specifically name appraisers, appraisal firms or appraisal management companies as defendants. That’s an important distinction because the appraisal industry has been fortunate that only a small fraction of litigation about financial losses blamed on appraisal deficiencies actually names any appraisal defendants. Yet, the stakes below are very significant for the appraisal industry because the realistic measure of damages at issue in just these 8 cases — not the plaintiffs’ puffed-up alleged damages — is...

HVCC & Interim Rules Unintended Consequences 7

NAIHP Letter Regarding Appraiser Independence Regulations

An outline exposing the unintended consequences created by HVCC and the Interim Rule February 23, 2012, Hon. Richard Cordray, Director, Consumer Financial Protection Bureau Re: Appraiser Independence Regulations Dear Director Cordray: Thank you for taking the time to meet with NAIHP on January 26, 2012. We always appreciate the opportunity to meet with the CFPB and discuss issues of concern that affect consumers and small business housing professionals. Although, our meeting covered a broad range of issues, my comments today are limited to the ongoing problems associated with “Appraiser Independence.” Today’s interim Rule on Appraiser Independence, was built on the...

Small business cash crunch 0

Small Business Cash Crunch

Appraisers & their frustration with cash flow… I recently attended the Association of Texas Appraisers (ATA) Mid-Year Meeting in New Braunfels, TX. I met many wonderful ATA members and the meeting was well organized.  Much of the meeting consisted of discussions on Texas Appraiser Licensing Certification Board (TALCB) commission activities, technology tools for appraisers, and USPAP. Since the topic of cash management rarely is presented in any appraisal meeting or event (but it should), I took the time during the networking sessions to learn more about the financial successes, struggles, and conditions of appraisers and their businesses. Some appraisers shared they are...

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Thing of Value

Pay for an assignment? “Never. It’ll never happen!” It happens all of the time. While most appraisers would never dream of violating the Management portion of the Ethics Rule by paying for work…many do it every day without giving it any thought. Management: An appraiser must disclose that he or she paid a fee or commission, or gave a thing of value in connection with the procurement of an assignment. Comment: The disclosure must appear in the certification and in any transmittal letter in which conclusions are stated; however, disclosure of the amount paid is not required. In groups or...

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