Category: The US Department of Veterans Affairs

Loans Affected by the $400,000 Appraisal Threshold Increase 2

Loans Affected by the De Minimus Increase

NCUA is advocating for an increase in the de minimus to $400K for loans provided by Credit Unions… The $400,000 de minimus is now ‘official’ but it doesn’t apply to most appraisals. Here’s an article from HousingWire, published on 10/8/2019, which correctly states when this change took effect, which you should read. From the article: Now, it’s important to note that the new rules do not apply to loans wholly or partially insured or guaranteed by, or eligible for sale to, a government agency or government-sponsored agency. What that means is that loans sold to or guaranteed by the Federal...

The Raising of the De Minimus and Its Impact on the Appraisal Industry 11

De Minimus Impact on the Appraisal Industry

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

Subject Street Scene Photos' Policy - Appraisers Blogs 13

Street Scene Photos of the Subject Property

Appraisers, the discussion of subject photos occurred recently on a forum I read. How many of you know the street scene “view” policy of FHA and FNMA? How many of you were trained to just take ONE photo from the very front of the subject, looking down the street in one direction or the other (without having the subject in the photo)? Is that ‘good enough’ for a lender to know the context of where the subject is on the street? If a ‘street view policy’ between agencies is more strict for one, would it be appropriate to adopt that policy for...

Landmark Acquired by Class Valuation - VA Drops 1004MC...Done Deal! 13

Done Deal

AMC Consolidaton – Class Valuation (formerly Class Appraisal) of Troy, MI is acquiring Landmark Network, of Van Nuys, CA. This document does not say ‘when’ it will occur, or if the transaction has concluded, but the way it is written, the implication is that it’s a “dun deel.” Anybody have any scuttlebutt on which of the hundreds of the remaining AMC’s might be next to be consolidated with another one? Landmark Network’s email: Hello! Eleven years ago, I set out to create a different kind of appraisal management company. One that truly valued our appraiser partners while embracing the efforts...

Comments Needed for Proposed Rule to Amend Appraisal Requirements 8

Comments Needed on Appraisal Requirement

The OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies’ regulations requiring appraisals for certain real estate-related transactions. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices. The proposed rule would make conforming changes to add transactions secured by...

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...

States Back LREAB Against FTC - FNMA Ends 1004MC - Stress Test Failed? 5

States Back LREAB Against FTC

States Support Louisiana Real Estate Appraiser Board against the FTC States (and appraisers) are very interested in the outcome of the LREAB vs FTC to protect their own sovereign actions. On July 11, 2018, the states of Mississippi, Idaho, Iowa, Rhode Island, and Utah filed an amicus brief with the United States Court of Appeals for the Fifth Circuit supporting the Louisiana Real Estate Appraiser Board. See the entire brief here or below. The outcome of this will impact each and every one of us. As we reported a few days ago, one lender, BB&T, has opted to step up...

Improper Direction to Appraisers as a New Special Lender Condition 21

Improper Direction to Appraisers

…specific prohibited direction to appraisers involved in federally regulated transactions… Improper direction to appraisers as a new special lender condition Honorable Ladies and Gentlemen: The following article appeared in a recent online post at http://appraisersblogs.com/appraisers-asked-2-overlook-weed-cultivation (also copied to this letter following our inquiry). We consider the original author to be a credible source. Due to the serious implications of any appraisal management service giving such specific prohibited direction to appraisers involved in federally regulated transactions we believe it to be our duty to bring this to your collective attention. We respectfully request that each Federal Regulatory Agency review this issue...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

Salary Range for Real Estate Appraisers in the US? 29

Average US Appraiser Salary

Are you curious about the salary range for appraisers in the United States? Click this link for info on salary ranges for Real Estate Appraisers. Rising fees across the country has fueled the growth in appraiser income. That’s a good thing! Why should we be the only ‘workers’ to have their income potential held down by lenders who don’t want to pass on true costs of doing complicated appraisals to their bank clients – the actual mortgage loan consumer – while EVERYTHING else has increased? Thankfully over the past two years that has changed, as most appraisers across the US...

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