Category: Dodd-Frank Act / C&R Fees

Mister 225 appraiser & VaCAP 27

Mr. $225 Appraiser and VaCAP

Mr. $225 Appraiser, you are a major contributor to the problem Recently VaCAP has been receiving correspondence from Virginia Appraisers complaining about low fees and AMC abuses. Comments like the “The AMC is taking more than half of my fee” and another “Why hasn’t VaCAP done something?” One of the best yet… ”When is the Customary and Reasonable Fee Committee meeting? I can’t keep accepting appraisals for $225“ This came two weeks after the Customary and Reasonable Fee Committee meeting! Well Mr. $225 Appraiser, what rock have you been under? VaCAP sends out information on a regular basis; on average...

Porter Ranch Environmental Issues 5

Environmental Issues Notice to Appraisers

Response to LRES email concerning appraiser’s responsibility regarding environmental issues Fellow Appraisers, Have you asked yourself WHY a few more of the larger regional AMCs are joining organizations like REVAA? In my opinion, it is because they and their clients (usually GSE lenders) KNOW that they are not truly compliant with Dodd-Frank’s C&R requirement. Despite disclaimers or advisories like this, they also know that the bulk of their work products are ‘probably not compliant’ with USPAP. Notices like this don’t normally get set out until ‘after the fact’ issues arise. REVAA recently helped coerce the State of Virginia (through threat...

Big data is in real estate 13

Big Data is in Real Estate

The only thing Big Data can’t do is smell. I got a call from my credit card company. Now I have been traveling a lot lately on business. Apparently, someone got my number and charged $199.53 at WalMart on Monday. I was not in WalMart, but a couple a weeks ago I bought a new TV at Sam’s Club. No question about the Sam’s Club purchase. How did they know I did not go to WalMart? I am truly amazed. The reason – BIG DATA! The banks are amassing massive amounts of data on you, me, everyone. They know more...

Board Member Says Squeaky Wheel Gets the Grease 2

Board Member Says ‘Squeaky Wheel Gets the Grease’

Board Members reported a shortage of individual appraisers offering suggestions, complaints and concerns… Legitimate ‘complaints’ should never be referred to as whining by any professional in my opinion. To do so diminishes the importance of the concerns being addressed. I attended the Las Vegas Public Hearing of the The Appraisal Foundation (TAF) / Appraisal Practices Board (APB) last Friday. No Appraisers Guild or member funds were used in any way for this. There was lots of good information. Board Members reported that there really is a shortage of individual appraisers offering suggestions, complaints and concerns to them as a Board,...

AMCs vs Public Interest - VaCAP Advocacy 29

AMC vs Public Interest – VaCAP Advocacy

Since the beginning, Federal Regulation of the industry was initiated to “protect the public. “ FIRREA, USPAP, HVCC, Dodd Frank and state licensing of appraisers and appraisal management companies were initiated with consumer protection as the goal. Customary and reasonable fees, mandated by Dodd Frank, are also to protect the consumer. The Virginia Coalition of Appraiser Professionals supports customary and reasonable fees and believes in order to determine a customary and reasonable fee all things associated must be considered and incorporated into the determination. The below practices by AMC’s are not in the interest of protecting public trust and go...

Appraisers and Their Lack of Fees - Appraisal Cost 12

Appraisers and Their Lack of Fees

I feel it’s only prudent to put my ten cents, or more, in on the subject of actual cost, versus paid fees for appraisals After an overwhelming outpouring of response from appraisers all over the country, I am compelled to write a follow up article to “Appraisals and The Real Cost of Doing Business.” I must stress that my original intent was to highlight the ever increasing cost in all aspects of our industry, passed on to our clients, due for the most part to increased compliance requirements, additional staffing required to monitor said compliance, Dodd Frank rules, HVCC, TRID...

Day Laborers Needed...Inquire at any AMC 6

Day Laborers Needed…Inquire at any AMC

Help Wanted – Day Laborers Needed …. Inquire at any AMC The Dodd Frank act requires the lender to be responsible for their agents. This means the lender is responsible for the actions of the AMC. Do the lenders know what their AMC’S are doing? Probably not. The Dodd Frank act also requires the most qualified appraiser be selected for each and every assignment. What vetting is done by the AMC’S to ensure the most qualified Appraiser is selected? Many AMC’S have the false mentality every appraiser is qualified and competent to appraise every piece of real estate. This simply...

VaCap Speaking out Regarding C&R Fees 8

VaCap Speaking out Regarding C&R Fees

CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs. AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession. In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement.   First, the Feds have made it very clear that lenders...

FFIEC Requested Action on TRID - Imagecredit Flickr - Johannes Ahlmann 6

FFIEC Requested Action on TRID

The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...

A Possible Solution to Customary and Reasonable Fees - C&R Fees Solutions 10

A Possible Solution to Customary & Reasonable Fees

Over the past five years, a major subject of talk in the appraiser world has been that of Customary and Reasonable Fees. Unfortunately, much of the dialogue has been mostly one-sided. We tend to do a lot of griping about the fact that many of us are not being paid what is “customary” or “reasonable”, but there are very few solutions offered up. When I was young and would sometimes (not often, of course) complain about this or that, my father would always say, “Don’t come to me with a complaint unless you have a possible solution.” It was sound advice then...

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