Category: Dodd-Frank Act / C&R Fees

Bias in Automated Valuation Models 11

Bias in Automated Valuation Models

The CFPB is reviewing bias in Automated Valuation Models (AVMs). The proposed rules are a joint effort by the Consumer Financial Protection Bureau, the Office of the Controller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Federal Housing Finance Agency. These agencies are concerned AVMs may reflect bias in design and function. The mathematical models rely on biased data resulting in inaccurate valuations. Basically the agencies are stating historical data going back to redlining is built into these models and do not reflect current market data. Remember markets are not static and are...

A New Standard for ROV Requests 22

A New ‘Standard’ for ROV Requests

Since beginning using this Standard, I have had ZERO ROV requests. Appraisers, the latest ‘buzzword’ around appraising is Standard. We’ve got to have a Standard for measuring a subject dwelling, even though the comparable GLA reported figure may have been measured far differently from the new soon-to-be mandated Standard. Appraisers have no way of controlling the apples to oranges dissimilarities. But I digress… According to the Dodd-Frank law, and the HVCC before it, clients are allowed to challenge the appraiser’s value opinion by submitting what is termed in the law “appropriate” sales to be further reviewed, with the expectation that...

Dear HUD... the Word Extortion Comes to Mind. What's Your End Game? 7

DEAR HUD… What’s Your End Game?

Dear HUD, recently, within the past year or so, you have been on a crusade to prove discrimination and racism in the appraisal process. Your actions haven’t gone unnoticed by many within the appraisal profession as well as outside it. It’s become clear that you are the go to organization for complaints. Ok. Please read this in its entirety and see my thoughts at the end before making a judgement. The reason I am writing you this letter is for a couple of reasons. First and foremost, I am writing this letter to ask you what your TRUE intentions are...

Waiting for the Platform to Fall... They Hired the Fastest Cheapest Guy 35

Waiting for the Platform to Fall…

…waiting for the platform to fall… because you know they hired the fastest and cheapest guy to build it! When Dodd Frank was implemented lenders started using appraisal management companies, eliminating appraisers relationships basically overnight. Appraisers embraced the change reluctantly and started accepting assignments from appraisal management companies. Over the years appraisal management companies showed their true colors and lowered fees, required appraisers to pay upload fees and forced many appraisers to pay for unnecessary back ground checks. Some have hired staff appraisers, completely disregarding the intent of Dodd Frank in an attempt to lower operating costs. Today, most AMC’s...

FTC's pursuit of the State of Louisiana cost the Appraisal Profession dearly 12

FTC Has Cost the Appraisal Profession Dearly

The FTC has cost the appraisal profession dearly in their pursuit of the State of Louisiana. This entire episode has been entirely misguided… The FTC’s time SHOULD have been spent investigating the AMC trade group known as REVAA to find TRULY non-competitive practices… The FTC is asking for public comments on the consent decree by the Louisiana Real Estate Appraisal Board. The time line to comment is short and ends on July 22, 2021. VaCAP asks each of you to take a few minutes and read the consent decree as well as the analysis provided by the FTC before commenting....

Bringing Back the Lost Art of Relationship Building - AppraisersBlogs 13

Relationships… The Lost Art

Relationships. It’s a lost art of business when it comes to the appraiser profession… I have been an appraiser since 2003, when I started my career path. Since then, the appraiser profession has gone through many changes, none more impactful than creating the Home Valuation Code of Conduct or HVCC law that was put into effect after the crash. HVCC created the new normal for the profession where Appraisal Management Companies (AMCs) were installed as the firewall or third party between the appraiser and the lender. Overnight on May 1st, 2009, appraisers all over the country lost every relationship they...

Appraisal Fees Back in the Spot Light 5

Appraisal Fees Back in the Spot Light

FTC vs LREAB Update The Supreme Court has denied the Louisiana Real Estate Appraisers Board’s petition to intervene in the administrative case for price fixing by the FTC. The FTC trial is scheduled to proceed on April 20, 2021. VaCAP is closely following this case and will update you as it proceeds. To view all the activity for this case, go to the FTC’s webpage here. Working RE Appraisal Survey Let your voice be heard on what is customary and reasonable fees for your services. Working RE is conducting the annual fee survey. We have been asked to help distribute...

Open Letter to Mortgage Lenders - Your Appraisal Management Company 22

Open Letter to Mortgage Lenders

How much vetting have you done on the appraisal management company? How involved are you as the lender in the day to day activities of the appraisal management company?… The world has changed and most everything in our lives involves technology. The technologies available to each of us are tools. They are not a more reliable means, merely more convenient. Human thought and analysis is still required in every aspect of life. When the Final Rules of the Dodd Frank Legislation went into effect, many lenders chose to use appraisal management companies with the false idea they had no liability for...

Appraisal Fee Price Fixing Claim Case to Reach the US Supreme Court 6

Price-Fixing Case May Reach Supreme Court

The first case about real estate appraisers to reach the U.S. Supreme Court in almost 60 years may concern the Federal Trade Commission’s price-fixing claims against the Louisiana Real Estate Appraisers Board. Would that be a good thing for appraisers? Well, maybe it’s not the best timing. Filed in 2017, the FTC’s administrative complaint asserts that the Louisiana appraiser board, “a state agency controlled by licensed real estate appraisers, has unreasonably restrained price competition for real estate appraisal services.” The FTC contends that the board carried out this price-fixing through its regulation of fees paid to appraisers by appraisal management...

Update on FTC’s Price-Fixing Enforcement Action Against LREAB 6

New Appellate Decision – LREAB v FTC

FTC’s price-fixing enforcement action against LREAB… A federal appellate court – the U.S. Court of Appeals for the 5th Circuit – has issued a decision in the long-standing fight between the Louisiana Real Estate Appraisers Board (LREAB) and the U.S. Federal Trade Commission about “customary and reasonable” appraisal fees. I’m venturing here to provide a short, understandable, unbiased summary of the litigation and what this latest court decision means. What did the Court of Appeals decide? Here’s the very short summary: The Federal Trade Commission (FTC) is pursuing an administrative complaint it filed in 2017 against LREAB, contending that LREAB’s “customary and reasonable”...

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