Category: Dodd-Frank Act / C&R Fees

AMC’s Filing Complaints Against Appraisers 1

AMC’s Filing Complaints Against Appraisers

AMC’s are sending in complaints on appraisers… From ICAP – Illinois Coalition of Appraisal Professionals “Good afternoon ICAP’ers, I am writing to our residential members regarding a growing problem that ICAP is concerned with regarding lenders and AMC’s filing complaints against appraisers. THE SETUP: You receive a call from a lender or an AMC who wants to talk to you about an appraisal assignment you recently completed for them. The call usually comes from the QC Department at the post closing stage of the loan. They start questioning you on your line item adjustments. All the comparables are on smaller...

ACOW / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Appraisal and AMC Fees Separated on Revised Settlement Forms 4

Appraisal and AMC Fees Separated on Revised Settlement Forms

The Consumer Financial Protection Bureau released the second proposed version of a new Consumer Disclosure Form Feb. 1 that includes clear disclosure of any fee paid to a “Local Appraisal Company” and to an “Appraisal Management Company.” The Appraisal Institute reported last month that the CFPB is in the midst of developing a new form that would replace the existing HUD-1 settlement statement. In December 2011, Appraisal Institute representatives met with CFPB officials about the new form. The CFPB has indicated that several versions of the proposed form will be developed and tested with consumers by focus groups, with a...

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

On Appraisals, Should You Follow the Money? 6

On Appraisals, Should You Follow The Money? Asks Kenneth Harney

Follow the Money Some appraisers are being paid less than half the fee, while the balance flows to an appraisal management company. Washington – The new Consumer Financial Protection Bureau is working on a real estate issue that gets to the core of the agency’s purpose: Bringing clarity and better disclosures about the often opaque and costly fees that homebuyers, sellers and refinancers are hit with at closings. One of the disclosures now under review might surprise you: appraisal charges. Why do they need clarifying? Doesn’t just about everybody who applies for a mortgage, whether it’s to buy a house...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Dodd-Frank Act / C&R Fees

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers 1

American Guild of Appraisers Files Request RE C&R Fees

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers WASHINGTON, Jan. 23, 2012 /PRNewswire-USNewswire/ On behalf of the American Guild of Appraisers, today the law firm Garvey Schubert Barer filed a request with the Federal Reserve Board under the Freedom of Information Act seeking a wide variety of documents related to the regulations on customary and reasonable compensation of fee appraisers that were issued by the Board in October 2011. In announcing this action, Guild President Peter Vidi said, “It is clear that appraisal management companies...

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

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 2

Appraisal Institute Seeks Separation of Appraisal and AMC Fees

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

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

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GAO Report on ASC Hits the Street

On January 18, 2012, the US Government Accountability Office (GAO) released their report on real estate appraisals “Appraisal Subcommittee Needs to Improve Monitoring Procedures” as required per Dodd-Frank. GAO was tasked with 1) determining how the Appraisal Subcommittee (ASC) is carrying out its Title XI responsibilities, 2) ASC’s plans to implement Dodd-Frank provisions, and 3) regulatory dollar thresholds for determining when an appraisal is required. GAO reports that one of the challenges faced by ASC is in the area of resources and planning. GAO cites the creation of a national hotline as one example of a Dodd-Frank requirement that could...

Appraisal / Appraisal News / Appraisal Subcommittee / Appraisers News / ASC / Dodd-Frank Act / C&R Fees

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 0

CFPB Appraisal Fees

ASA has repeatedly stated its belief that the Fed’s interpretation and the massive loophole it created ran contrary to the plain language and clear intent of Dodd-Frank. CFPB Reissues Interim Final Rule On Valuation Independence, Eliminates Federal Reserve Commentary Permitting AMCs To Include Their Own Payments To Appraisers To Comply With Dodd-Frank’s Customary and Reasonable Fee Requirement. On December 22, the Consumer Financial Protection Bureau (CFPB) released an Interim Final Rule dealing with the valuation independence requirements imposed by the Dodd-Frank Act, including the law’s “customary and reasonable” fee mandate. The CFPB’s rule was republished to reflect the transfer of...

AMC / American Society of Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News

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“Public Trust Betrayed”

Congresswoman Jackie Speier letter to author of “Public Trust Betrayed” James E. Manning, author of “Public Trust Betrayed”, an appraiser in California who began his career in 1973, received a letter from Congresswoman Jackie Speier in response to his book and the state of the appraisal industry: December 30, 2011 – Mr. James Manning Dear Mr. Manning: Earlier this year you offered me a copy of your book, Public Trust Betrayed.  After some delay, I have finally had an opportunity to briefly review it. I agree with many of your conclusions. For example, you indicate that existing laws created after...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

Flawed Appraisals Killing Sales 2

AI Response to NAHB on Appraisals Killing Home Sales

The Appraisal Foundation Responds to NAHB December 8 Press Release on ‘Flawed Appraisals Killing Home Sales’ December 13, 2011  – Paul Lopez – National Association of Home Builders (NAHB) Dear Mr. Lopez: We are contacting you in reference to the attached NAHB press release dated Thursday, December 8, 2011, entitled, Flawed Appraisals Killing Home Sales, Hampering Housing Recovery. As the Congressionally-authorized organization that establishes appraisal standards and appraiser qualifications in the United States, we feel compelled to address  aspects  of the press release we feel need clarification. The  press  release  quotes  NAHB  Chairman  Bob  Nielsen  as  stating,  “The  inappropriate  use ...

Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / Dodd-Frank Act / C&R Fees / NAHB

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FDIC Publication Focuses on Real Estate Valuation Programs

Issues related to real estate appraisal and valuation programs are of critical interest to bankers and regulators. “Navigating the Real Estate Valuation Process,” which appears in the Winter 2011 issue of Supervisory Insights released on December 14, 2011, highlights certain aspects of the 2010 Interagency Appraisal and Evaluation Guidelines (Guidelines). This article also provides information for bankers regarding sound practices for banks’ real estate valuation processes in the areas of valuation review, independence, content standards, preparer selection, and monitoring. “Banks have implemented provisions of the Guidelines, but continue to seek feedback from their regulators on appraisal-related concerns,” said Sandra L. Thompson, Director, Division of...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

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