Tagged: Consumer protection

Comments Needed for Proposed Rule to Amend Appraisal Requirements 6

Comments Needed on Appraisal Requirement

The OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies’ regulations requiring appraisals for certain real estate-related transactions. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices. The proposed rule would make conforming changes to add transactions secured by...

Open Letter to Taxpayers... Afterall, Taxpayers Aren’t Stupid 32

Open Letter to Taxpayers

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

Has Mortgage Lending System Improved Due to AMCs? 34

The AMC Dog and Pony Show

From the HVCC to today, can we really say the mortgage lending system has improved due to AMCs? The AMC dog and pony show has been going on for the better part of a decade. Appraisers have been called out for every problem associated with a real estate closing. Ever silent is any talk of better educating Realtors®. They are the ones with the most power in the pricing process, and the majority of so-called “appraisal problems” are because they say it’s a problem. That’s a LOT of power. But somehow, they manage to stay under the radar and no...

Deal Falls Through & Everyone Blames the Appraiser - AppraisersBlogs 12

Blaming Appraisers

…deal falls through and everyone involved is convinced the appraiser ruined everything… We hear all about low appraisals, but we never seem to hear about homes that are flat-out over priced, often by an agent who wants to prove they are smarter than everyone else and will take advantage of any unusual feature or circumstance to push the value beyond any other homes in the local market. For example: A buyer finds a house in need of some updating. Medium sized market and things are selling between 90-120 days on average. The neighborhood is good and the house has a...

Are You a Hybrid Appraiser? Relying on Real Estate Trainees... 23

Are You a Hybrid Appraiser?

We won’t take appraiser trainees, but we’ll take real estate trainees… That’s the million dollar question. Big banking is counting on the majority of appraisers to fall in line with whatever hybrid product they decide is best. It makes for an interesting road ahead because appraisers actually have the power to make these products a success or a failure. A hybrid appraisal is still an appraisal and must have a signature from a licensed appraiser. If banks can keep whittling away at the appraiser’s scope and can get the total appraisal fee low enough, they will achieve their goal and...

MISMO Blueprint... The Evil Octopus - AppraisersBlogs 4

The Evil Octopus

Appraisers, it’s not paranoia when ‘the bastards’ really are out to get you (end us as a profession). …Find each octopus and how they relate to our jobs. Look at MISMO Directors list… An Open Letter to Appraisers: Residential & Commercial This started as a response to a blog post by a respected appraiser concerning the influence of AMCs. During drafting it was clear that trying to explain AMCs was only part of the bigger struggles we face today. Picture a violent “all in” three-way gang fight among Octopi. Say a dozen on each side. That’s 36 Octopi x 8 tentacles...

Let’s just use the Tax Assessments...Tax Values just as Accurate as AVMs? 22

Tax Values Just as Accurate as AVMs?

In a head to head contest between tax values and AVMs for use in mortgage lending, I’ll take tax assessments every time… The battles rage on to decide who will take over the automated valuation process. There are big companies lining up to take over this massive profit arena. And, make no mistake, it’s all about the money. At the end of every discussion about AVMs verses traditional appraisals, it has less to do with faster or cheaper, or better, and sadly little to do with consumer protection. It has to do with who gets the profits that will be...

TriStar Bank Nuclear Option DENIED! FTC vs LREAB in Circuit Court 16

Nuclear Option DENIED!

VaCAP has just been informed the TriStar Bank Waiver Request has been DENIED by the ASC. Representatives from VaCap attended the TriStar bank appraisal waiver hearing at the Federal Reserve building in DC this morning. Also present were John Russell with the ASA-NAIFA, Leo Regensburg with the AGA, Bill Garber with the AI, Mark Shiffman with REVAA, appraisers and other stake holders. The board members consisted of Robert Witt with the FHFA, Veronica Spicer representing the CFPB, Richard Taft representing the OCC, and ASC board members. The meeting got off to a late start because the Tri-Star representatives were held...

Financial Reform Legislation in Terms of What it Does For or To Appraisers 12

Bridging The Gap

I’m an appraiser. I look at all proposed financial reform legislation in terms of what it does for, or to appraisers. Not whether it was proposed by a red or a blue. Dear AppraisersBlogs readers and fellow appraisers; Anyone who has read my past posts is aware I happen to be a Republican Union Organizer. Usually it isn’t an issue because I try to remain non partisan in my posts and to avoid offensive partisan rhetoric, while promoting appraisers rights; the American Guild of Appraisers, and being critical of bad lending policy and bad appraisal practices. I have also attempted...

ASC Call for Comments: Dangerous Slippery Slope if Waiver is Granted 6

ASC Call for Comments

It is important for every appraiser to submit comments… The Appraisal Subcommittee wants to hear from appraisers on Tristar Bank’s request for appraisal waivers. The comment period is open until April 9, 2018. VaCAP has previously participated in a group letter with other organizations and expressed our concerns on this topic. We will once again be part of a group letter as well as send in our own comments. It is important for every appraiser to submit comments on how this is a dangerous slippery slope if the waiver is granted. Consumer protection is the issue and the door will be...

xml sitemap