On July 9, 2013 I participated in a radio interview with a lobbyist for the 100 largest financial firms. The San Francisco radio program host asked me what question I would ask the lobbyist and I said that any discussion should begin with allowing him to state his view of what caused the crisis. In the course of his explanation, he bemoaned the fact that there was no warning about the crisis.
I found this ironic because I had just published that morning an article about how the appraisal profession warned us that the senior officers controlling the mortgage lending firms were engaged in pervasive “accounting control fraud.”
That article discussed the ten logical implications about the developing fraud epidemic that any competent financial regulator could have explained to FBI agents and Assistant U.S. Attorneys (AUSAs) on the basis of the facts contained in these two sentences:
“From 2000 to 2007, [appraisers] ultimately delivered to Washington officials a petition; signed by 11,000 appraisers…it charged that lenders were pressuring appraisers to place artificially high prices on properties. According to the petition, lenders were ‘blacklisting honest appraisers’ and instead assigning business only to appraisers who would hit the desired price targets” (FCIC 2011: 18).
Note that the appraisers’ petition (more…)
The National Association of Independent Housing Professionals (NAIHP) led by Marc Savitt is petitioning the Consumer Financial Protection Bureau and is asking those harmed by the Interim Final Rule on Appraiser Independence to sign and forward the online petition.
To Consumer Financial Protection Bureau (CFPB), Richard Cordreay, CFPB Director: Allow NMLS loan originators to order appraisals (more…)
Please consider signing the online petition launched by John Dingeman opposing the coercive and abusive behavior of Chase Bank and other lenders against appraisers.
Stop Intimidating, Threatening, and Bullying Appraisers
Chase Mortgage Banking, like other financial institutions have come into possession of appraisals where a loan has been assigned or sold to them. If Chase had any issues with these appraisals during the underwriting process when the loans were written, they would have asked the appraiser’s “Client” for clarification, explanations, and/or corrections.
With every foreclosure, Chase is scrubbing each and every one of the appraisals in an attempt to place blame on a loan gone bad on someone else, instead of acknowledging their culpability in greed. Chase is sending out non-registered mail and alleging that USPAP (Uniform Standards of Professional Appraisal Practice) violations occurred and are asking the appraiser to reconcile the violations, explain their appraisal methodology, and discuss with them the value conclusion. If the appraiser does not comply, Chase is threatening the appraiser with placement on their Ineligible Appraiser List and a formal complaint to the respective appraisal board. (more…)
Please consider signing the online petition launched by appraisers and written by George Hatch, opposing the use of AMC fees as Customary & Reasonable:
Federal Reserve Board to Clarify Customary and Reasonable Appraisal Fees
On October 18, 2010, the Federal Reserve Board announced an interim final rule to Regulation Z of Title 12, also known as the Truth in Lending Act (TILA). One of the elements to Regulation Z is a binding requirement upon creditors and appraisal management companies to ensure that appraisers who are not employees of creditors or of the appraisal management companies receive customary and reasonable payments for their services.
In preparing this interim final rule, the Federal Reserve Board did not specifically identify which appraisal fee schedules, surveys or studies that would be appropriate to designate as a ‘‘safe harbor’’ for creditors and their agents to comply with the reasonable and customary fee requirements of TILA. (more…)