Tagged: Appraisal Management Companies

Proposed Rule for AMCs 0

Proposed Rule for AMCs

Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...

Online Petition to Make a Difference in Customary and Reasonable Appraisal Fees 5

Customary & Reasonable Appraisal Fees

A Cost-Plus fee structure will allow the Customary and Reasonable Fee provision, a component of Appraiser Independence, to be more readily adopted. Fellow Professional Appraiser, I am asking you to take a moment from your busy day to PARTICIPATE in an important industry effort. That issue is referred to within Title XIV of the Dodd-Frank legislation as “Customary and Reasonable Fees”: CUSTOMARY AND REASONABLE FEE In General – Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such...

Appraisal Quality Determined by AVMs 7

Appraisal Quality Determined by AVMs?

…So, now we can check to see if appraisals are accurate by checking them against Automated Valuation Services? Wow! That’s frightening on so many levels. Remember the “garbage in, garbage out” articles about using AVM’s? Many AVM’s are close to useless. “Relevant data,” really, like an AVM? Gimme a break! Hard to get passed this on and it’s flat out crazy. If computers could price real estate accurately, the appraisal industry would have died out years ago…

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Non-Lender Valuation: Consumers Should Tread Carefully

Competition, in a free market, is a fierce catalyst: one that can effectively sort out the bad apples from the bunch. Capitalism works, it is simple when left unfettered and when all parties are ethical in their approach to business. It works until politicians, however well meaning they try to be, step in with a”solution”. Through the Dodd-Frank reform and the Andrew Cuomo created Home Valuation Code of Conduct that predates Dodd-Frank, congress effectively went anti-small business again. I liken this profession’s recent undermining by congress to how they saw to sort out the small-family farmers by paving the way...

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Blacklisted? How to Get Reinstated

There is a high cost of being blacklisted. When a lending institution loses confidence in an appraiser’s work, the bank or AMC will put them on a “do not use” list, also known as a blacklist. In some cases, this means an appraiser has made a costly mistake. However, some banks are taking blacklisting to an extreme by treating appraisers as guilty until proven innocent without cause or reason why. If unchallenged, this practice can be devastating because being blacklisted even once can have permanent detrimental effects on an appraiser’s career, income, and reputation. By engaging in blacklisting lenders are...

Call to action DPOR AMC hearing 1

DPOR AMC Public Hearing CALL to ACTION

CALL to ACTION: DPOR Public Hearing for Initial Appraisal Management Company Regulations Thursday, February 27, 2014, DPOR is holding a public hearing on the proposed Initial Appraisal Management Company Regulations. The hearing will begin at 9:00AM in the DPOR  meeting room at 9960 Maryland Dr, Richmond. The new regulation establishes definitions, qualifications, fees, and standards of practice and conduct for appraisal management companies. The new regulation is required to implement Chapter 405 of the Acts of the 2012 General Assembly, which resulted from HB 210. The goal of the regulation is to establish qualifications, fees, and standards of practice and...

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URAR 1004s Are for Sissies

1004s are for sissies I remember the first time I ever saw a real appraisal report.  No, I am not talking about a 1004, 2055, or even a 1025.  I am not referring to a Fannie or Freddie form at all. I mean a real, living, breathing, monster of a report; the narrative!!! (insert collective gasp here) Early in my career, one of my insightful instructors brought one of his narrative reports to class.  As I perused that 76 page beast full of words (not boxes), descriptions (not canned comments), graphs (not pre-filled MC Addendums), and pictures (oh, how there were...

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“Fake” Appraiser E&O Insurance and Shady Things from AMCs Too

Outright Fake E&O For many appraisers and also some AMCs (appraisal management companies), the only reason they purchase professional liability insurance (E&O) is because a client requires them to show coverage in order to receive work.  The fact that some appraisers and AMCs only look at insurance as an “E&O ticket” leads to some unfortunate examples of fraud, which appraisers, firms, AMCs and clients should be aware of. Before I get to the fakery, however, I’ll explain that our purpose in providing E&O, and also the reason that most of our insureds purchase it, is because E&O first serves the insured by providing...

Assigning Blame 0

Assigning Blame

Even though the redirection of blame is an ancient approach to avoid taking responsibility for ones one actions, this seemingly innocuous tactic has become the leading downfall to the financial industry today. Consider, the consequences of shifting blame: The actual party who has made poor lending decisions escapes taking responsibility, and often times will even get promoted. Thus the initial behavior does not change. Since the poor decision has not been corrected, the pattern will continue. Redirecting the blame combined with the continuation of the faulty decisions expands the direction of investigation, because now a larger pool of appraisers appear...

Fannie Mae Lender Letter 0

A New Year, a New Fannie Mae Letter

New Fannie Mae Lender Letter I get it, appraising, especially residential-mortgage-use appraising, can be a thankless job. If you understand all that goes into properly developed reporting, it is hard to compete with the appraisers that perform poor due diligence and in turn, charge much less than the rest of us. They are great at checking boxes and making minimal commentary. They are rewarded for cutting corners, and appraisers that do the quality work are left at the margins. The new Fannie Mae Lender Letter may be a step in changing this. Our costs to keep our licenses with the continuing education, the...

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