Compliance Notification to AMCs

VaCAP Board

VaCAP Board

Coalition of Appraisers in Virginia at Virginia Coalition of Appraiser Professionals
Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.
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VaCAP AMC Compliance Notification

Virginia Coalition of Appraisal Professionals’ Courtesy notification to AMCs licensed in Virginia

On Monday March 29, 2016, VaCAP sent via email a courtesy notification to each AMC licensed in Virginia along with a copy of the Guidance Document issued by the Department of Professional Occupation Regulation. They will follow up with a hard copy to each licensed AMC next week as well. VaCAP continues to Unite, Preserve and Promote the collective interests of all appraisal professionals in the Commonwealth of Virginia.

To all Licensed AMCs in Virginia:

This correspondence is intended as the Virginia Coalition of Appraiser Professionals (VaCAP) courtesy notification to your firm of the Virginia Real Estate Appraisal Board’s recent adoption of a presumptive minimum of compliance regarding the mandatory payment of customary and reasonable appraisal fees in the Commonwealth of Virginia as mandated by 54.1-2021.1.B.22.k and 54.1-2022.1 of the code of Virginia and 18 VAC 130-30-160.15 of the Board’s Appraisal Management Company Regulations. VACAP represents appraiser members across the Commonwealth of Virginia, and serves to promote public confidence in the appraisal profession as one of its central tenets.

On February 23, 2016, the Virginia Real Estate Appraisal Board formally adopted the Veterans Administration Fee Schedule as a presumptive minimum compliance threshold. The ruling is intended to bring AMC related appraisal activity into compliance with the federal Dodd-Frank Law and Virginia Legislation. This action ultimately protects the consumers of the Commonwealth of Virginia.

The Board’s ruling clearly outlines a minimum presumption of compliance with customary and reasonable fees as the Veterans Administration Fee Schedule in effect at the time an appraisal order is placed. The Virginia Real Estate Board further emphasized the fee correlates to the scope of work required for a typical appraisal performed in conjunction with the Veterans Administration requirements. The Virginia Real Estate Appraisal Board provided further clarification by emphasizing that any expansion of the scope of work beyond the Veterans Administration assignment scope of work (such as requests for additional comparables, active/pending listings, cost approach development, graphs, charts, etc.) additional compensation to the appraiser to reflect that additional work is due.

As a professional courtesy, please forward the attached Guidance Document issued by the Department of Professional and Occupation Regulation to your lender/clients to ensure their understanding of the minimum compliance of the Code of Virginia and the Board’s Regulation.

Sincerely,
The Virginia Coalition of Appraisal Professionals

Image credit flickr - Indie Photos
VaCAP Board

VaCAP Board

Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.

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9 Responses

  1. jack connor says:

    I can’t imagine an AMC surviving paying these fees. We may end up with the round robin method of assignment after all.

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    • Donna Taylor says:

      Jack,

      I think you are missing something here.  The AMCs should not be making THEIR profit off of the appraisers fees.  If my fee is $500 and the AMC fee is $150 than the borrower will have to pay $650 for an appraisal PERIOD.  If the lender thinks this is to much then they have the option of having an in-house ordering department or they can use something like Mercury Network which charges I think $13 to $15 per order.  It’s not the appraiser’s job to make money for the AMC.

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  2. Chris says:

    The VA has a very simple ordering system. Its goes on a rotational order. Very simple to upload the reports.

    How hard could it really be to have a similar ordering system in place at each lenders. All the nonsense would stop immediately !

    Or use Alamode. They are the best of course.

    Greedy Banks, that’s all !

    Stick to your guns appraisers, times are achanging !

    Thank you Virginia coalition !!!

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    • Retired Appraiser Retired Appraiser says:

      HVCC and it’s constant renaming was never about common sense or protecting the public, but rather about creating annual multi-billion dollar profit centers for banks through their AMC subsidiaries. Many appraisers, including myself, were suggesting using the VA fee schedule and a similar method of rotation as far back as 2009.

      As amazing as Virginia’s seven year miracle may be, I still wouldn’t touch the business with a 100,000 mile pole. With all of the new requirements (1004MC, UAD crap, Collateral Undertaker, and the latest HUD requirements, and unlimited liability) I would have to see at least $800 for a basic ranch appraisal to even consider rejoining the “profession”..

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  3. bill johnson says:

    With the sell of Forsythe Appraisals to First American mortgage, perhaps they saw the writing on the wall. Will other states offer similar regulation, thus undercutting their business model? Time will tell.

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    • Baggins - The Truth Is Out There Baggins - The Truth Is Out There says:

      Is First AM still alive? Remarkable. Have not heard mention of those guys in a very long time. Perhaps I’m better insulated than I used to be. Truth be told, you do not need to live in Virginia, to make power moves when it comes to client choices. All that is necessary is will power, perseverance, and the ability to call down the list and market more broadly. If the amc’s and even on amc distributors can do that, certainly so can the appraisers.

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  4. KenQ says:

    Are AMC’s doing business in Virginia paying $450 for appraisals? Can anyone in Virginia confirm this?

    What about iMortgage, Coester, Clear Capital and the like? Are they paying $450 or still shopping for $200 appraisals?

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    • bubba jay / Retired Appraiser II bubba jay / Retired Appraiser II says:

      Clear Capitol called me last year. when i asked about their fees, they told me something like $350-400. about a week after getting signed up with them, i started getting orders in the $200-250 range, and properties WAY outside my coverage area. it didnt take me long to tell them to “stick it”.

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Compliance Notification to AMCs

by VaCAP Board time to read: 2 min
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