Category: Dodd-Frank Act / C&R Fees

Appraisal news for real estate appraisers and real estate professionals regarding Dodd -Frank Act and Customary and Reasonable appraisal fees. News relating to the Appraisal Industry.

Recap of the 4th Appraisal Bias Hearing 9

Recap of the 4th ASC Appraisal Bias Hearing

On February 13th, 2024, the fourth ASC appraisal bias hearing took place. For those who were unable to attend, the video of the hearing has been included below. The hearing was a crucial event for the appraisal industry, and it is important for all appraisers to be aware of the discussions and topics addressed. The panel of witnesses included: David Bunton, President, The Appraisal Foundation E.C. Neelly IV, Executive Director, Mississippi Real Estate Appraisal Board Maureen Sweeney, Principal, Maureen Sweeney, Real Estate Appraiser Ltd. Melissa Tran, Director, Texas Appraiser Licensing and Certification Board Jillian White, Chief Executive Officer, Appraisal Insights...

AMCs Billing Scheme, Hidden Profits & Deceptive Practices 72

AMCs Billing Scheme, Hidden Profits & Deceptive Practices

Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace for appraisal orders.  Appraisal Management Companies (AMC’s) do not pass on cost savings for reduced appraisal services to consumers. Instead, they keep the savings for themselves without disclosing the amount to the consumer or the appraiser. What should have been cost savings for the consumer are pocketed by the AMC in secret. This is considered a junk fee or unearned fee billing scheme under current law. Appraisers who participate in this system are in violation of The Management Rule of...

AMCs Violating TILA and C&R Fee Clauses 81

AMCs Violating TILA and C&R Fee Clauses

Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA) and the Customary and Reasonable fee clauses. This has not only caused harm to consumers but also to appraisers who are struggling to make a living. Despite efforts to bring this issue to light, it has been largely hidden from the public and regulators. However, it is time to change that and reveal the truth about what is really happening. To do so, we need to gather more data and evidence to establish a pattern of violations for these bids...

Racial Bias Complaint Filed Against Me 47

Seller Filed a Racial Bias Complaint Against Me

So what’s caused the sudden loss of income? Could it be because of the racial bias complaint filed against me by an unhappy Seller…  Fannie Mae accomplished what they set out to do in July 2011, when they initiated their Uniform Appraisal Dataset (UAD) and the Uniform Collateral Data Portal. The goal was to collect enough property data to effectively remove appraisers from the home buying and refinancing process. It all started with Dodd-Frank Act, a several hundred pages Act signed into law by then President Obama, sold to unsuspecting Americans as a protection from the corrupt business practices of...

It’s a Great Time to Leave the Appraisal Profession 138

Leaving the Appraisal Profession

It’s a Great Time to Leave the Appraisal Profession. I can hear the chorus of my fellow appraisers rising up in disagreement with me. I envision many of them screaming, “But I love being an appraiser”! Yeah, I hear you. I loved being an appraiser too. Let’s not consider what we were but what they want us to become. First, ask yourself if you are still making a livable wage. I’m not and instead of blaming myself, I started running the numbers. In, my high value market, 18% of the solds were cash sales. No appraisal required on those! Values...

AMC Engagement Letter: Do Not Include Your Invoice 16

AMC Engagement Letter: Appraisers Do Not Include Your Invoice

File the complaint against the AMC yourself OR Forward the engagement letter to VaCAP to file on your behalf.  At the recent Virginia Appraisal Board Meeting on Wednesday June 28th, a discussion occurred about Appraisal Management Companies prohibiting appraisers from including their invoices with the appraisal report. The overall consensus of the Board Members was this practice could be a violation of Virginia Appraisal Management Company Statute § 54.1-2022 B. “B. The appraisal management company shall not prohibit an appraiser from disclosing in the appraisal report the actual fees charged by an appraiser for appraisal services, and shall otherwise comply...

AMC Fee Impact on Appraisal Fee 78

AMC Fee Impact on Appraisal Fee

While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394.  We often hear complaints from GSEs and lenders that appraisal fees are too high, hence the push for modernization. Yet they fail to acknowledge that this is due to an overly bloated middleman – the appraisal management company (AMC). As a consumer, you should be aware of the potential for being fleeced on appraisal fees. It’s possible that you could be paying more than double what the appraiser is receiving for actually doing the work, with the excess going to...

Dear Representative, FNMA Has Gone Rogue! 87

Dear Representative, FNMA Has Gone Rogue!

Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending purposes is nothing more than wanton recklessness that could have serious repercussions in the future. The truth of the matter is that appraisals are an essential part of any mortgage transaction and should not be taken lightly or eliminated without due consideration. Without them, there can be no assurance as to whether a homebuyer will get what they pay for or if lenders will make bad investments with their money. In short, waiving/eliminating property appraisal requirements puts everyone at risk...

Look in the Mirror 15

Look in the Mirror

The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is a powerful statement that can evoke a range of emotions and reactions from individuals, from contemplation to defensiveness. At its core, the phrase is a call to examine oneself honestly and objectively. It asks us to step back from our assumptions, biases, and preconceptions and consider our behavior, choices, and beliefs in a critical light. When we take a look in the mirror, we are forced to confront our flaws and shortcomings, but also to recognize our strengths and achievements....

Opportunity to Work for Free is Not a Plan 73

‘Opportunity’ to Work for Free is Not a Plan

I gave this ‘opportunity’ further critical analysis in terms of time spent versus the fee income potential.  Appraisers, I’d like to disclose a personal ‘opportunity’ that was presented to me last fall, early winter. A company with AMC roots was, or is, recruiting people to become “property inspectors” with the resulting reports potentially fed to other appraisers who do HYBRID, or maybe even DESKTOP reports. The GSEs never intended the DESKTOP report to incorporate separate ‘property inspections’ from a hired third party, but that’s been the evolution because they just look the other way. Last fall, due to the slowdown...

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