Category: FDIC

When an Appraisal is Not Required - Appraisals & Evaluations Regs 4

Appraisals NOT Required

…is not required to obtain an appraisal under other law… The Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter to US banks on 10/16/18, which incorporates Appraisal and Evaluation regulations and guidelines. This consolidates previously issued regs and guidelines into one document: Letter  FIL-62-2018 Part 323 – Appraisals Appraisal and Evaluation Guidelines 2000 – Rules and Regulations PART 323—APPRAISALS § 323.3 Appraisals required; transactions requiring a state certified or licensed appraiser. (a) Appraisals required. An appraisal performed by a state certified or licensed appraiser is required for all real estate-related financial transactions except those in which: (1) The transaction value is $250,000 or less;...

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 24

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

Increasing use of AMS to replace AMCs 15

Increasing use of AMS to replace AMCs

AMS on fast track to replace AMCs… Well, it looks like the detritus of HVCC has finally come full circle. AMS (services vs companies) are on the fast track to replace AMCs. AMCs that foster their use haven’t realized that yet. They have given the lenders the tools needed to avoid costly appraisal management oversight departments while at the same time giving them the ability to use only those appraisers willing to make the deals work. They mistakenly believe that by delegating to an AMS or AMC they have met their due diligence requirements.Quality control? Sure. Just ignore the FNMA...

LREAB Response to FTC Allegations 15

LREAB Response to FTC Allegations

FTC seeking to punish LREAB for following federal regulatory mandates… BATON ROUGE, LA (May 31, 2017) – In an administrative complaint filed today by the Federal Trade Commission (FTC), it was alleged that the Louisiana Real Estate Appraisers Board (LREAB) had fixed the minimum price of residential real estate appraisals by enforcing the Board’s obligations under federal law to ensure that appraisers are paid customary and reasonable fees for their services. Bruce Unangst, Executive Director of the Louisiana Real Estate Appraisers Board (LREAB), said: “Respectfully, the FTC is just plain wrong. By issuing this legally faulty and factually incorrect complaint,...

Low AMC Fees? FDIC Wants to Hear from Appraisers 24

Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

AMCs paying low fees, Appraisers and Regulation Z of TILA VaCAP recently learned of some encouraging news. The FDIC wants Regulation Z to be followed and will enforce it for appraisers. Here is what VaCAP received from an appraiser who reached out to the FDIC: I just had a call from an extremely pleasant lady named Susan Welch from the FDIC Consumer Response Center (1-800-378-9581). I had sent a note over regarding an AMC attempting to get me to sign a “Base Fee Letter” agreeing to a drop of my base fee for full appraisals to $325 from $400-500. She...

Comments Continue to be Invited - Appraisers Call to Action 6

Should the Government Accept Appraisers’ Complaints?

If you believe the government should be accepting complaints from appraisers regarding Appraiser Independence Issues, then please send your comments Please respond to the call to action below! The IACF was developed for use by those who wish to file a formal, written complaint that an entity subject to the jurisdiction of one or more Agencies, the Board, or the NCUA has failed to comply with the appraisal independence standards or USPAP. The IACF is designed to collect information necessary for one or both of the Agencies, the Board, or the NCUA to take further action on a complaint from...

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...

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...

Beware of Appraiser Karma - Llano Cases - Imagecredit Flickr - Doug Geisler 7

Beware of Appraiser Karma – Llano Cases

In our world of claims involving appraisers, we quite often see different versions of this same story — in this version of the story, an appraiser did a review appraisal that was used by Savant LG in a currently pending case against another appraiser in Florida. Just months later, that appraiser found himself named as a defendant in a lawsuit filed…

Appraisers Participation Needed - NMAC Tackling BPO & CU Issues - Imagecredit Flickr - Miles Heller 2

Appraisers Participation Needed – Tackling BPO & CU Issues

The appraisal industry was blindsided once again only this time by the AG’s office when they determined that the Real Estate Appraiser Board cannot regulate BPO’s. The New Mexico Appraiser’s Coalition and the Rio Grande Chapter of the Appraisal Institute sent a joint letter to the Appraisal Board prior to a hearing that was held in January to discuss the BPO language in the Appraiser Act. Although we feel we provided enough information to guide the Board, the Attorney General Representative at the meeting made the determination that the Appraisal Board had no jurisdiction over the BPO product. Even though...

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