Category: Dodd-Frank Act / C&R Fees

Eliminate the Appraisal Subcommittee too! Appraisal Institute Effort to Eliminate the ASC 38

AI’s Effort to Eliminate the ASC!

Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...

Appraisal Regulations - Life After Dodd-Frank ~ copyright AppraisersBlogs 5

Life After Dodd-Frank

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

The Partisan Battle to Eliminate Dodd Frank 15

The Partisan Battle to Eliminate Dodd Frank

Dodd Frank created the illusion… I had a different “take away” from the Housing and Insurance Subcommittee “Modernizing Appraisals” hearing. My impression was that there were two simultaneous hearings by the same people in the same place. There was the actual televised hearing with disparate prepared speeches, and then there was the real underlying reason for the hearing. The partisan battle to eliminate Dodd Frank. I try very hard to take a non partisan approach to the issues facing appraisers when writing about or for the American Guild of Appraisers (AGA). Obviously AGA is a union organization, though as I’ve...

Modernizing Appraisals: It seems we're stuck in 1989. 46

Modernizing Appraisals & Being Stuck in 1989

Modernizing Appraisals: It seems we’re stuck in 1989… On November 16, 2016, the Housing and Insurance Subcommitte held a hearing on “Modernizing Appraisals: A Regulatory Review and the Future of the Industry.” Subcommittee discussed modernizing appraisals to benefit American consumers. The hearing focused on necessary changes to the appraisal industry. Subcommittee Chairman Blaine Luetkemeyer (R-MO) explained: “Appraisals are one of the cornerstones of the home-buying process. Issues that impact appraisers also impact nearly every American buying or selling a home, in rural and urban areas; in high- and low-income neighborhoods. Yet when it comes to the regulatory regime surrounding appraisals,...

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 38

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

AMC Indemnification & Catchall Certification 7

AMC Indemnification

Appraisers signing off catch-all certification… When we crafted the language in the AMC Act back in 2011-2012, we followed what most every other state included insofar as indemnification was concerned. (225 ILCS 459/165) Sec. 165. Prohibited activities. (8) Requiring an appraiser to sign any sort of indemnification agreement that would require the appraiser to defend and hold harmless the appraisal management company or any of its agents, employees, or independent contractors for any liability, damage, losses, or claims arising out of the services performed by the appraisal management company or its agents, employees, or independent contractors and not the services performed...

Appraisers Just Say No to Certain Assignments From Certain Clients 32

Appraisers Just Say No to Certain Assignments From Certain Clients

Some appraisers just say no and refuse to do assignments for low echelon AMCs fishing for cheapest and fastest appraisers… Folks, A very experienced Chief Appraiser, Mr. Greg Stephens, for the largest independently owned appraisal company in the US, Metro-West, has had an article published in National Mortgage Professional magazine, about the state of affairs concerning the so-called “appraiser shortage.” You can read the article here. While this article reveals important details based on appraiser population facts, there is a glaring omission. The omission is relative to “why” certain mortgage lending assignments are being delayed. It is different, and perhaps...

AMC Vendor Agreement Controversies - Bad, Worst & Ugly AMCs 42

Vendor Agreement Controversies & Worst AMCs

AMC Vendor Agreement Controversies – Bad, Worst & Ugly AMCs And the winner is… According to a recent non-scientific survey conducted by AppraiserNews, the World’s Worst AMC Alive is Clear Capital. Honorable Mention goes to Coester VMS and Streetlinks. And the Worst Vampire AMC title goes to AppraiserLoft which is no longer operational. Excerpt: We’d also like to note the passion with which appraisers made their votes, describing the many ways that these AMCs deserved their titles! One final remark: It is sad that so many appraisers still hesitate to go public with their comments about AMCs, (justifiably) fearing that...

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Twisted AMC & C&R Fees Gone Wrong!

This AMC is Just Wrong & Confused! An AMC sent an appraiser the following email this morning: “…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“ Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the...

Expert Witness AMC Order Blast & Appraiser's Response 5

Expert Witness AMC Order Blast & Appraiser’s Response

AMC’s order blast for Expert Witness Appraisal Services Before I can offer ANY bid, you folks need to decide whether you want a FNMA 1004 form, a 1073 form or a 1025 form. If the latter is sought, then a 1004MC would not appear to be relevant. I am expert witness qualified in Los Angeles County Superior Court. In addition to the base fee (due in advance) which starts at a minimum of $1,500 for SFR, $2,000 for a condo and $2,500 for a 2 to 4 unit rent controlled property in Los Angeles, I charge $350 an hour for...

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