Tagged: ASFMRA

Exterior Appraisals & Temporary Appraisal Guidelines During COVID-19 16

COVID-19 Temporary Appraisal Guidelines

Fannie and Freddie are giving preference to desktop appraisals over exterior appraisals, which quite frankly, is completely backwards from what most appraisers believe to be a more reliable appraisal. HUD and the Veterans Administration, on the other hand prefer exterior appraisals…

Feds Deny Public Hearing - Denial of a Public Hearing is Undemocratic 16

Feds Deny Public Hearing

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied  the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...

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Response to "A Wakeup Call for the Valuation Industry: Is anybody listening?"

RE: Richard Gilmore, ARA article – "A Wakeup Call for the Valuation Industry: Is Anybody Listening?" I would like to offer some comments regarding Mr. Gilmore’s article in the April 9, 2013 issue of Ag News. I also read most of the NAHB report – "A Comprehensive Blueprint For Residential Appraisal Reform" dated February 2013. I disagree with most of Mr. Gilmore’s comments regarding the NAHB report. The NAHB report lacks a realistic understanding of what is taking place in the real estate appraisal profession today. Most of what is commented on in the NAHB report has been required and/or in place for more...

A Wakeup Call for the Valuation Industry: Is anybody listening? 8

A Wakeup Call for the Valuation Industry: Is Anybody Listening?

On February 13, 2013 the National Association of Home Builders (NAHB) published a fascinating critique on the world of valuation. The document: “A Comprehensive Blueprint for Residential Appraisal Reform” should be read by every appraiser, every user and every client. NAHB is telling us our core systems are not working and to take another look at our process and procedures. Our systems are too inconsistent, too cumbersome, and NAHB is asking us to improve our efficiency which impacts their and our profitability. NAHB is asking the industry to provide them a uniform, consistent, quality product utilizing well trained staff. These exact...

Appraiser Complaint Forms 0

AI Advocates for Issue-Specific Appraiser Complaint Forms

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 28 to the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Comptroller of the Currency expressing concern about the broad reach of a proposed Interagency Appraisal Complaint form. The agencies intend to provide a copy of the form to individual complainants, who, in turn, will return to the agency for information gathering and potential referral. In its letter, AI and ASFMRA expressed concern that the proposed form may not be the most effective approach and instead recommended complaint forms...

ASC letter RE Launch of the 0

Appraisal Hotline Operations Details

Appraisal Institute Wants Details on Appraisal Hotline Operations The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 12 to the Appraisal Subcommittee asking that it make its proposed protocol for operating the “appraisal hotline” available for public comment prior to its March 29 implementation. In the letter, AI and ASFMRA said that while the concept of a hotline is sound, there exists almost no understanding among state appraiser regulatory officials, practicing appraisers and real estate and mortgage professionals as to how the hotline would function or even of its intended purpose....

Lenders May Still Profit Most from Appraisal Fees 2

To Disclose or Not to Disclose AMC Fees

To Disclose or not to Disclose AMC Fees… With the Consumer Financial Protection Bureau (“CFPB”) up and running, there are numerous regulatory issues still pending relating to the Dodd-Frank Act. The regulatory issues include appraisal independence rules, AMC fee disclosure, AMC registration, required physical property visit by appraisers in “higher risk” mortgages, HUD-1/RESPA Consumer Disclosure, and asset backed securities. Of particular note, the CFPB has proposed a new Consumer Disclosure form that is intended to replace the HUD-1 settlement statement. The proposed rule which was release for public until November, allows disclosure of appraisal management company fees, but does not...

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AI Asks HUD to Withdraw Section 8 Provision Eliminating Appraisals

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers issued a comment letter July 16 in response to the U.S. Department of Housing and Urban Development’s proposed rule on regulatory changes to their Section 8 Voucher Program. The rule proposes to eliminate an existing requirement that an appraisal be used to determine initial rent contracts to a Section 8 building owner. HUD cited a “lack of availability of state-certified appraisers” and “increased expenses in order to acquire state-certified appraisers” as the reasons for eliminating the appraisal requirement. In their joint letter, AI and ASFMRA asked HUD...

Appraisal Institute Continues to Support Separation of Fees 1

AI Continues to Support Separation of Fees

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers reiterated their support of separating appraisal and appraisal management company fees on mortgage disclosure forms June 20 in Congressional testimony. The organizations originally voiced support when drafts of the Consumer Financial Protection Bureau’s proposed Consumer Disclosure Form were released in February. AI and ASFMRA again expressed their support in written testimony on “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses” before the House Committee on Financial Services’ Subcommittee on Insurance, Housing and Community Opportunity. The organizations expressed support of clear disclosure of...

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 2

Appraisal Institute Seeks Separation of Appraisal and AMC Fees

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

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