Tagged: Appraiser Independence Requirements

The Partisan Battle to Eliminate Dodd Frank 15

The Partisan Battle to Eliminate Dodd Frank

Dodd Frank created the illusion… I had a different “take away” from the Housing and Insurance Subcommittee “Modernizing Appraisals” hearing. My impression was that there were two simultaneous hearings by the same people in the same place. There was the actual televised hearing with disparate prepared speeches, and then there was the real underlying reason for the hearing. The partisan battle to eliminate Dodd Frank. I try very hard to take a non partisan approach to the issues facing appraisers when writing about or for the American Guild of Appraisers (AGA). Obviously AGA is a union organization, though as I’ve...

AMC Indemnification & Catchall Certification 7

AMC Indemnification

Appraisers signing off catch-all certification… When we crafted the language in the AMC Act back in 2011-2012, we followed what most every other state included insofar as indemnification was concerned. (225 ILCS 459/165) Sec. 165. Prohibited activities. (8) Requiring an appraiser to sign any sort of indemnification agreement that would require the appraiser to defend and hold harmless the appraisal management company or any of its agents, employees, or independent contractors for any liability, damage, losses, or claims arising out of the services performed by the appraisal management company or its agents, employees, or independent contractors and not the services performed...

AIR Statement - Revision Requests 4

AIR Statement & Revision Requests

AIR Statement & Changes to a Completed Report I would like some of the experts to comment on the following: Scenario Here is a scenario: The lender request that the appraiser include an AIR statement in the completed report. Sometimes they even have a preprinted statement that you must include in the report. The appraiser completes the report and includes the required AIR statement. The AMC reviews the appraisal and send back a revision request. They want comp # 4 removed from the appraisal. Maybe they provide you with another sale that they want you to include in the report....

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Network of State Appraisal Orgainzation’s letter to FHFA Director Watt Regarding Fannie Mae Collateral Underwriter (CU) Program

For over the past couple of months, VaCAP has participated with 18 other State Appraiser Coalitions in drafting an unified response to Fannie Mae’s Collateral Underwriter Program. Their letter to FHFA Director Watt briefly outlines their concerns, offers recommended solutions, as well as asking for a meeting to discuss the issue for the benefit of all vested parties. Please take a few minutes to peruse the letter below: Dear Director Watt: On behalf of the independent state professional appraiser organizations signing below, I invite your attention to concerns expressed by the majority of real estate appraisers regarding Fannie Mae’s announcement...

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

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Fannie Mae’s Appraiser Quality Monitoring List FAQs

Appraiser Quality Monitoring Information Fannie Mae has published a new web page with information about the recently implemented Appraiser Quality Monitoring (AQM) process. The new AQM web page includes FAQs and a link to the AQM list identifying appraisers whose appraisals will be subject to 100% review by Fannie Mae or whose appraisals are no longer accepted by Fannie Mae. The AQM list is protected content, and approved Fannie Mae sellers/servicers may set up access through Technology Manager. Appraiser Quality Monitoring (AQM) FAQs Fannie Mae began collecting appraisal data in 2011 through the Uniform Collateral Data Portal® (UCDP®). Millions of...

In response to appraisers under attack 2

In Response to “Appraisers Under Attack”

In response to Frank Garay and Brian Steven’s commentary (see video below), on the lawsuit against TriMavin AMC over alleged appraisal independence violations, an anonymous commentator posted the following: There are a number of posters here who need to re-take their CE classes including the moderators. Here are the reasons the entire industry is severely broken. I mean from the Realtor to the Appraiser to the Mortgage Lender. First of all HVCC sunset folks – back in 2010. It was replaced with AIR (Appraiser Independence Regulations) and the Dodd Frank Act. Cannot tell you how irritating it is to me...

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline 1

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline

The establishment of an appraisal complaint hotline… The American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) appreciate the opportunity to jointly comment on the Paperwork Reduction Act implications of the establishment of the Appraisal Complaint Hotline system mandated by section 1473 of Dodd-Frank. Although we understand that the public will have an opportunity to comment on the appraisal complaint form itself when it is proposed (described as “the Interagency Appraisal Complaint Form”), we believe the agencies’ October 22nd Federal Register request for comment provides our organizations (and other stakeholders) with an important opportunity to...

Letting the AIR out 4

Letting the AIR Out!

After all it’s AIR; not a vacuum. First, HVCC is dead. Dead and buried. It died back in 2010. Second, even when it was still plaguing the profession, it never stated that appraisers couldn’t or shouldn’t talk to real estate agents or brokers. Ever. I still have a copy of the HVCC because you never know when revisionist history will appear. Eventually, AIR took its place. AIR stands for Appraiser Independence Requirements. I have a copy of AIR. It resembles HVCC in many ways but, again, it doesn’t say a single word about appraisers being prohibited from chatting up or...

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