Category: Customary & Reasonable Fees

Lenders May Still Profit Most from Appraisal Fees 3

Revealing AMC Fees Optional Under Proposed Disclosure Forms

On July 9, the Consumer Financial Protection Bureau released its proposed rule for mortgage disclosure forms designed to help consumers shopping for a home loan. The CFPB also showed the latest versions of its loan estimate form and its closing form. Part of the CFPB’s “Know Before You Owe” mortgage project, the proposed rule includes two forms that borrowers will receive after applying for a mortgage but before closing on their homes. The Appraisal Institute previously had expressed its support for the new forms, but asked that the CFPB separate the appraisal fee from the appraisal management company fee to...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

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Regulators Should Take Actions to Strengthen Appraisal Oversight

Fed Report Scrutinizes Appraisal Processes The Government Accountability Office released a report June 28 that scrutinized real estate valuations in the wake of the recent mortgage crisis. The report, Residential Appraisals — Regulators Should Take Actions to Strengthen Appraisal Oversight, was produced using data from Fannie Mae, Freddie Mac and five of the biggest mortgage lenders. The report revealed that valuations received through broker price opinions and automated valuation models take less time and are less costly than traditional appraisal reports, but traditional appraisal reports are still mandated for almost all first-lien residential loan originations due to their greater reliability....

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

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Home Appraisers Complain that New Regulations Hurt the Housing Market

On June 28, 2012 appraisers, appraisal organizations, and others testified before the US House of Representatives, Committee on Financial Services, Subcommittee on Insurance, Housing and Community Opportunity, on proposals to improve oversight, regulation, and enforcement of the housing appraisal process. Among the topics addressed were the implementation of new financial service regulations under the Dodd-Frank law, appraisal fraud, the role of state regulators, and oversight of the appraisal process at the local level. The topic of the hearing was Appraisal Oversight: The Regulatory Impact on Consumers and Businesses. You will can read the testimony by clicking on the following link.

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

AGA Statement to House Financial Services Committee Hearing 3

AGA Statement to House Financial Services Committee Hearing

The American Guild of Appraisers Statement to House Financial Services Committee Hearing Madam Chairman and Members of the Committee, on behalf of the American Guild of Appraisers/OPEIU Guild 44 (AGA) thank you for the opportunity to submit this statement in connection with today’s hearing on the real estate appraisal profession and the regulation of appraisers and appraisal practice. The AGA is a membership organization that seeks to represent the interests of appraisers related to federal and state regulation of appraisal practice and to industry practices that impact on appraisers and appraisals. In addition, working closely with other like-minded organizations including...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Appraisal Institute Continues to Support Separation of Fees 1

AI Continues to Support Separation of Fees

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers reiterated their support of separating appraisal and appraisal management company fees on mortgage disclosure forms June 20 in Congressional testimony. The organizations originally voiced support when drafts of the Consumer Financial Protection Bureau’s proposed Consumer Disclosure Form were released in February. AI and ASFMRA again expressed their support in written testimony on “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses” before the House Committee on Financial Services’ Subcommittee on Insurance, Housing and Community Opportunity. The organizations expressed support of clear disclosure of...

AI / AMC / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal Management Companies

Statement of Frank Gregoire (NAR) Before Appraisal Oversight Hearing 3

Statement of Frank Gregoire (NAR) Before Appraisal Oversight Hearing

NAR believes that lenders should be prohibited from retaining the services of an AMC where the lender maintains any level of ownership. Frank Gregoire‘s written testimony to the United States House of Representatives Committee on Financial Services Subcommittee on Insurance, Housing and Community Opportunity before the Appraisal Oversight Hearing … APPRAISAL ISSUES AND CHALLENGES There are a myriad of circumstances and issues working to hinder the recovery of the nation’s housing market. Among them, and often overlooked, are those related to the credible valuation of real property. A credible valuation provided by a licensed or certified professional 1) ensures the...

1004MC / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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20 Reasons Appraisers Should Get Paid Full Fee

JIM THORPE, Pa., May 24, 2012 /PRNewswire/ — Rick Grant of RGA Public Relations and Jeff Schurman of Leading Causes have released an industry white paper entitled “The Appraisal Management Company Full-Fee Hypothesis.” This is the first paper in a series the two plan to write in 2012, while also working with a number of mortgage technology thought leaders to produce other papers. “I’m very proud of the work we’ve done on this paper,” said Grant. “While the conclusions we have reached are bound to stir up controversy, this is an issue the industry needs to start taking very seriously....

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

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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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Subcommittee

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...

AMC / AMCO / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

American Guild of Appraisers Petitions Fed 0

Fed Petitioned by American Guild of Appraisers

American Guild of Appraisers Petitions Fed and Consumer Financial Protection Bureau to Overturn Regulation that Threatens Viability of Professional Appraisal Practice WASHINGTON, Feb. 23, 2012 /PRNewswire-USNewswire/ — The American Guild of Appraisers (AGA), a national organization of real estate appraisers that is an affiliate of the AFL-CIO’s Office and Professional Employees International Union (OPEIU), has petitioned the Federal Reserve Board (“Fed”) and the Consumer Financial Protection Bureau to overturn a regulation adopted by the Fed that is contrary to the Dodd Frank Financial Reform law, threatens the viability of professional appraisal practice and undermines the legitimacy of real estate appraisals...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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