Category: CFPB

Could the CFPB Eliminate AMCs? End of AMCs Fast & Cheap Mentality? 10

Could the CFPB Eliminate AMCs?

Will this be detrimental to appraisal management companies that operate under the fast and cheap mentality?… Let’s face it, the appraisal management company will not survive with quality appraisals at a reasonable and fair fee… The Consumer Financial Protection Bureau is seeking public comments on the proposed rules for a Qualified Mortgage. The proposed rules require the lender to season the mortgage for 36 months before they can sell it to Fannie or Freddie. What that means is the lender will own that loan for 3 years. Fast forward if the new rule goes into effect… The lender will be...

CFPB Wants to Eliminate the Debt to Income Requirement - Not AGAIN 5

Playing Fast and Loose With Credit?

CFPB is moving forward with proposing to eliminate the Debt to Income requirement… Appraisers, prepare yourself for what we are about to share. The short sighted proposal is simply nonsensical from every angle. The Consumer Financial Protection Bureau wants to eliminate the Debt to Income requirement on Qualified Mortgages. You may recall this was proposed a while back and most of the profession objected strongly. Letters, emails and phone calls were made and this absurdity went away. Earlier today CFPB Director, Kathy Kraninger announced the CFPB is moving forward with proposing to eliminate the Debt to Income (DTI) requirement and...

Hard Fixed Appraisal Fee in TRID - Possible Changes by CFPB 19

TRID – Possible Changes by CFPB

For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser… Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans. Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments....

Lenders Want to Eliminate DTI Cap! What Could Go Wrong? 20

Lenders Want to Eliminate DTI Cap!

No DTI CAPS – What could go wrong? Well, the insanity continues. HousingWire is reporting that a coalition of lenders and trade groups are calling on the CFPB to eliminate the debt to income cap on all qualified mortgages. Yes, you read that right. Lenders want to eliminate the debt to income cap to allow more loans to be originated. They claim by using alternative factors to determine risks, more low income borrowers can obtain a mortgage. Mortgage Bankers Association President and CEO Robert Broeksmit stated: With respect to the 43% DTI threshold, it makes little sense to commit to a rigid requirement...

The FDIC Says NO to Appraisals - Appraiser Connections AMC Folds 10

FDIC Says NO to Appraisals

The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...

Another Huckster Enters the Appraisal Arena 20

Another Huckster Enters the Appraisal Arena

Yet another third party huckster has entered into the real estate appraiser and appraisal arena. It’s that time again! Yet another third party huckster has entered into the real estate appraiser and appraisal arena. Apparently motivated by pure altruism. We identified a need in the marketplace to address a common problem that lenders are regularly challenged with in providing accurate appraisal quotes and then ensuring pricing on the Loan Estimate is consistent and compliant,” stated Vladimir Bien-Aime, president and CEO at Global DMS. (I LOVE this guy, he writes like me!) Global DMS Launches SnapVal to Provide Instant, Accurate, Guaranteed...

Appraisers Disappointed at Federal Banking Agencies - Appraisers Blogs 21

Appraisers Disappointed at Federal Agencies

I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. We knew that when we joined with others in signing the letter. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

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...

TriStar Bank Nuclear Option DENIED! FTC vs LREAB in Circuit Court 16

Nuclear Option DENIED!

VaCAP has just been informed the TriStar Bank Waiver Request has been DENIED by the ASC. Representatives from VaCap attended the TriStar bank appraisal waiver hearing at the Federal Reserve building in DC this morning. Also present were John Russell with the ASA-NAIFA, Leo Regensburg with the AGA, Bill Garber with the AI, Mark Shiffman with REVAA, appraisers and other stake holders. The board members consisted of Robert Witt with the FHFA, Veronica Spicer representing the CFPB, Richard Taft representing the OCC, and ASC board members. The meeting got off to a late start because the Tri-Star representatives were held...

Financial Reform Legislation in Terms of What it Does For or To Appraisers 12

Bridging The Gap

I’m an appraiser. I look at all proposed financial reform legislation in terms of what it does for, or to appraisers. Not whether it was proposed by a red or a blue. Dear AppraisersBlogs readers and fellow appraisers; Anyone who has read my past posts is aware I happen to be a Republican Union Organizer. Usually it isn’t an issue because I try to remain non partisan in my posts and to avoid offensive partisan rhetoric, while promoting appraisers rights; the American Guild of Appraisers, and being critical of bad lending policy and bad appraisal practices. I have also attempted...

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