Should the Government Accept Appraisers’ Complaints?

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.
VaCAP Board

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Comments Continue to be Invited - Appraisers Call to Action

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 an appraiser, other individual, financial institution, or other entities. The Agencies, the Board, and the NCUA use the information to take further action on the complaint to the extent the complaint relates to an issue within their jurisdiction. The Board and the NCUA are renewing their forms separately.

he OCC and FDIC estimate that the burden of this collection of information is as follows:

OCC

OMB Control Number: 1557-0314.
Estimated Number of Respondents: 1,500.
Estimated Burden per Response: 0.5 hours.
Estimated Total Annual Burden: 750 hours.

FDIC

OMB Control Number: 3064-0190.
Estimated Number of Respondents: 200.
Estimated Burden per Response: 0.5 hours.
Estimated Total Annual Burden: 100 hours.

The Agencies issued a notice regarding the collection for 60 days of comment on December 4, 2015, 80 FR 75896. No comments were received. Comments continue to be invited on:

(a) Whether the collection of information is necessary for the proper performance of the functions of the Agencies, including whether the information has practical utility;

(b) The accuracy of the Agencies’ estimates of the burden of the collection of information;

(c) Ways to enhance the quality, utility, and clarity of the information to be collected;

(d) Ways to minimize the burden of the collection on respondents, including through the use of automated collection techniques or other forms of information technology; and

(e) Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.

If you believe the government should be accepting complaints from appraisers regarding Appraiser Independence Issues, then please send your comments as follows:

All comments received, including attachments and other supporting materials, are part of the public record and subject to public disclosure. Do not include any information in your comment or supporting materials that you consider confidential or inappropriate for public disclosure.

FDIC: You may submit comments by any of the following methods:

  • Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.
  • Agency Web site: http://www.FDIC.gov/regulations/laws/federal/.
  • Mail: Gary Kuiper (202.898.3877), Counsel, MB-3016, or Manuel Cabeza (202.898.3767), Counsel, MB-3105, Legal Division, Federal Deposit Insurance Corporation, 550 17th Street NW., Washington, DC 20429.
  • Hand Delivered/Courier: The guard station at the rear of the 550 17th Street Building (located on F Street), on business days between 7:00 a.m. and 5:00 p.m.
  • Email: comments@FDIC.gov.

Instructions: Comments submitted must include “Interagency Appraisal Complaint Form.” Comments received will be posted without change to http://www.FDIC.gov/regulations/laws/federal/, including any personal information provided.

Additionally, please send a copy of your comments by mail to:

OCC Desk Officer, 1557-0314 or 3064-0190, U.S. Office of Management and Budget, 725 17th Street NW., #10235, Washington, DC 20503, or by email to: oira_ submission@omb.eop.gov.

Click here for more info.

If you belong to an Appraiser Organization, please pass this along.

Image credit flickr - alexisnyal
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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6 Responses

  1. Jeff Weeks says:

    There has been an over reach with certain lenders with respects to value in our area. Specifically Flagstar Bank and Dart appraisal where they question values on almost every appraisal completed. To the point they request an enormous amount of support and by the end of the report have an additional report provided to question the value provided. Directly questioning the value through underwriting and attempt to sway values by relentless revision request for additional support. Again by the end all they are questioning is the value provided. I can see where a new appraiser may be influenced by their underwriters to actually change the value due to the relentless pressure they are putting on appraisers in this area.

    Jeff Weeks

    Angel Fire Appraisers, LLC

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    • Tom D says:

      how much are you getting for the sub-report.  flagstar was once reasonable, when hvcc started their amc rep said i had to be more competitive. in calif they were getting $125.  you got your company name wrong jeff, if you work for them should be hell’s fire burning appraisers, llc. it’s the pot you choose to be cooked in i guess.

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  2. Retired Appraiser Retired Appraiser says:

    They have no problem accepting your complaints, just be aware that someone being paid minimum wage has been instructed to file all complaints in the nearest trash can as soon as they come in.

    60,000+ letters were delivered from appraisers to the U.S. government in 2009 by Alamode.

    *The Result:  Silence

    Two major petitions were circulated among appraisers in 2009 & 2010, each achieving similar numbers to the Alamode campaign. Both were delivered to the proper government officials.

    *The Result: Silence

    My office delivered letters to every member of Congress about the future of appraising in 2009.

    *The Result: Silence

    I personally delivered six boxes of research on the destruction of the appraisal industry to Senator Jim Bunning’s office in 2009 and requested a meeting with his majesty.

    *The Result:  Silence

    If silence is golden folks…give lenders and the government the ABSOLUTE SILENCE that they deserve.  If you can’t agree to boycott AMCs then walk away and have the last laugh. Those tiny fee gains that you’ve imagined ($400 to $200 to $300) are a temporary distortion of reality based on ultra low interest rates. Rates are now scheduled to rise in June; where do you see your fees going when mortgage applications and refinancing evaporates?

    I am now convinced that appraisers awaken each morning and repeat the following Appraiser’s Creed on the way to work: “I am an appraiser. My time is worthless. I am a slave to the mortgage industry. I shall not revolt against my master”. How else can you explain this inability to organize and revolt against injustice? Absolutely spineless.

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  3. Not yet a retired appraiser says:

    I was having an upbeat day.  Thanks Debbie Downers!  Just kidding.

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  4. Jeff Weeks says:

    Haha that’s perfect, Not yet a retired appraiser, I just told my wife this morning man things sure are going good, I wonder whats going to happen today to screw it all up. So far so good though. Guess im just getting use to the monotony.

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Should the Government Accept Appraisers’ Complaints?

by VaCAP Board time to read: 2 min
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