Category: CFPB

AMC Dangers: Appraisal Management Companies (AMC) are changing how our profession works 4

AMC Dangers to the Consumer

Appraisal Management Companies (AMC) are changing how our profession works. It’s important to know exactly how they are affecting the real estate process, especially if you are a home-owner, looking for real estate or are involved in another part of the property. Who does an Appraiser work for? An appraiser works for “The Client” named in the report who ultimately responsible for the appraiser’s compensation. It is important to realize that while a borrower may have paid a lender or third party the cost of the appraisal, “The client” remains the only party authorized to use the report. The appraiser...

Appraisal Fee Disclosure - Call To Action - CFBP requesting comments 8

Appraisal Fee Disclosure – Call To Action

Important – Call to Action This must be done by Tuesday July 7 The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. We feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee. Recently 23 state appraiser coalitions including the Louisiana Appraisers Coalition worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the...

Truth-in-Lending Act - RESPA Ingetraged Disclosure - TRID Coming Soon Imagecredit Flickr - Dennis Skley 1

TRID Coming Soon Your Way

Appraisers and others, TRID is coming to mortgage lending on Aug. 1, 2015. In case you have not been paying attention to new aspects surrounding your typical measuring buildings and writing reports on a daily basis, TRID is set to become a major change in the mortgage lending process. TRID is the acronym for the ‘Truth-in-Lending Act/RESPA Integrated Disclosure’ process that applies to every mortgage loan as of 8/01/15.  It was part of the Dodd-Frank Law, with power given to the CFPB agency to devise the rules, forms and process. The intent is to consolidate and simplify processes that have...

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Appraisal Management Company Sued in Consumer Class Action Complaint

A consumer class action complaint has been filed against a lender and its AMC relating to the subject matter of a prior CFPB investigation and settlement. Last August, the Consumer Financial Protection Bureau (CFPB) announced that it had taken action against Amerisave Mortgage Corporation, its affiliated AMC Novo Appraisal Management Company, and one of the owners of both companies Patrick Markert. Part of the CFPB’s action concerned alleged overcharging for appraisal services by the AMC and failure to disclose the AMC’s affiliation with the lender. Under a consent order, Amerisave and Novo agreed to pay $14.8 million in refunds to consumers and a $4.5 million...

CFPB Fines AMC for Inflated Appraisal Fees 2

CFPB Fines Lender, AMC for Inflated Appraisal Fees

The CFPB has ordered Amerisave and Novo to pay $14.8 million… The Consumer Financial Protection Bureau (CFPB) announced Aug. 12 that it fined mortgage lender Amerisave Mortgage Corp., its affiliate, Novo Appraisal Management Company, and the organizations’ collective owner, Patrick Markert, $19.3 million for allegedly luring prospective borrowers with misleading interest rates and trapping them with inflated appraisal fees. The CFPB claimed that the lender and its affiliated AMC violated the Truth in Lending Act and Real Estate Settlement Procedures Act by enticing tens of thousands of borrowers with deceptive advertising and then illegally overcharging them for third-party services. The...

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

The Appraisal Profession & Appraiser's Business Decimated by the Increasing Dominance of Appraisal Management Services - AMCs 15

Appraisal Profession Decimated by Appraisal Management Services

The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...

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Minimum Requirements for AMCs

Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...

Proposed Rule for AMCs 0

Proposed Rule for AMCs

Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...

Online Petition to Make a Difference in Customary and Reasonable Appraisal Fees 4

Online Petition: Customary & Reasonable Appraisal Fees

A Cost-Plus fee structure will allow the Customary and Reasonable Fee provision, a component of Appraiser Independence, to be more readily adopted. Fellow Professional Appraiser, I am asking you to take a moment from your busy day to PARTICIPATE in an important industry effort. That issue is referred to within Title XIV of the Dodd-Frank legislation as “Customary and Reasonable Fees”: CUSTOMARY AND REASONABLE FEE In General – Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such...

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