Mortgagee letter on choosing FHA appraiser, AMC &/or 3rd party fees… Does HUD have a Better Understanding of the Role of AMCs? Recently an old HUD/ FHA mortgagee letter has resurfaced. The mortgagee letter, 2009-28 has to do with choosing a FHA approved Roster Appraiser and Appraisal Management Company and / or Third Party Organization Fees. This mortgagee letter specifically states “the fee for the actual completion of an FHA appraisal may not include a fee for management of the appraisal process any activity other than the performance of the appraisal.” This mortgagee letter was written prior to the Final Rules and...
Allowing associated trainee appraisers to complete unsupervised inspections… Appraisers, and others, A ‘significantly large’ nationwide AMC has notified it’s vendor appraisers that certain lenders contracted with this AMC will now accept appraisal reports signed by properly trained (and presumed properly approved by the State) Trainees as the ‘Appraiser.’ This follows the Jan. 31, 2017 FNMA announcement that they will accept reports signed by Trainees. So far, I have not seen any similar announcement from FrMAC, FHA, VA, or USDA, or any other specific lender. The AMC’s message to their appraiser panel is below. NOTE: This memo says the Trainee is...
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...
FHA Case Transfer FHA Appraisers, The document below was issued yesterday by HUD FHA. Sometimes clients will ask appraisers to ‘put the report into the new lender’s name’ if the lender changes within the allowed time frame for a current appraisal. With FHA, the Case Number and the existing report STAYS WITH THE PROPERTY ADDRESS. The appraiser does not have to re-do a FHA report when the lender changes, per this in the document below: Working with Case Transfers Mortgagees should note the following about case transfers relative to appraisal reports in both the EAD portal and FHAC: If, prior...
Tell them what it will take to get you to re-start FHA assignments. FHA Appraisers, A new ‘attitude’ survey about doing FHA assignments has been prepared by the Illinois Coalition of Appraiser Professionals (ICAP). ICAP has a planned meeting with FHA, and will use survey results in their discussion. ICAP has asked that I distribute this, and by association, anyone who gets this may re-distribute via any other outlet, email list, etc. Link to the survey. It will take 4 minutes +/- to do this survey, depending on if you add additional comments at the end. One item the survey...
Advice from the Virginia Association of Realtors Legal Hotline Mack Strickland, a dedicated founding member of VaCAP, recently contacted the Virginia Association of Realtors Legal Hotline concerning FHA inspections. He shared with VaCAP his findings. “I called VAR legal hotline, a service to all REALTORS (appraisers are REALTORS too if paying dues). I inquired about the liability of the FHA inspection protocol of operating appliances. The lawyers confirmed my belief that to reduce the appraiser’s liability as to operation of appliances and equipment is to have a responsible person present to operate the appliances for the appraiser. I have adopted...
Lenders’ Requests, C&R Fees, Email Blasts, SOW, Unlicensed AMCs and more… What is the best way to ensure you receive a customary and reasonable fee for an appraisal? Answer: Only accept assignments with a customary and reasonable fee! That being said, here is a reminder of a USPAP requirement to consider before you respond to that email or text blast…. Scope of Work Rule Identify the problem to be solved. Determine and perform the scope of work necessary to develop credible assignment results. Disclose the scope of work in the report. Comment: Scope of work includes, but is not limited...
Licensed Residential Appraiser out of work! I find it hard to believe that there is a shortage of appraisers when I, a Licensed Residential Appraiser, have only completed three (3) appraisal assignments for 2016. I am constantly denied approval by Banks and AMCs. I’ve been denied because I am Licensed. I’ve been denied because I am not Certified. I am not being denied work because I am incompetent or because I have not been USPAP compliant. Certainly not because I have been disciplined. FHA removed Licensed Residential Appraisers. Then Banks and AMCs were eager to follow. I do not see...
FHA appraisers, When the new 4000.1 Handbook and associated Data Delivery Guide were released not long ago, astute readers noticed that FHA showed that they wanted the Comparable’s prior transactions to be reported back in time THREE YEARS, not just 1 year as per the form. Well, guess what? That apparently was an error, because the REVISED Data Delivery Guide, Effective Nov. 5, 2015, has that corrected back to ONE YEAR, which ‘sort of’ corresponds with the info on the GSE forms. Eagle eye readers will note there may still be an error with this! The form says …the year prior to...
FAQ PDF Document In June 2015, the Denver HOC conducted a webinar (or perhaps live class) training on the ‘then upcoming’ new FHA 4000.1 Handbook. Questions were submitted, and the answers were compiled into a FAQ PDF document (posted at the end of this article). Many of the questions were submitted by underwriters or other non-appraisers, but some were from appraisers. You will have to read through the 8.5 page FAQ PDF attachment to find appraisal related info. However, the one question and answer below may help alleviate the fears of some appraisers: Q. Does the appraiser have to note...
