Tagged: Consumer protection

North Dakota Bankers Seeking to Eliminate Consumer Protection Benefits 4

ND Banks Seeking to Kill Consumer Protection

…North Dakota bankers seeking to eliminate consumer protection benefits associated with appraisals… The real issue of concern to all appraisers is the attempted con job and subtle coercion by officials and State Senators in North Dakota over the ASC. In their letter to ASC regarding their appraisal waiver request, they cite only 170 ‘in area’ appraisers while excluding a hundred so-called out of the area (multiple state licenses). While North Dakota is about the 19th largest state in land area, it is the fourth lowest in overall population. The 2018 population was only 760,077! That makes it among the lowest...

Loan Officer' Letter Instructing Borrower to Push Appraiser for Value 36

A Little Push Can’t Hurt Right? Wrong!!

…forget the risky position foisted on the consumer by the loan officer… Well, here we go again. In my previous blog posts titled “Round and Round” and “Pressure My Story”, I spoke to examples of how lenders and/or AMCs have been pushing and pressuring appraisers to hit certain values on transactions. If an appraiser did not hit these numbers, or make changes to make the transaction work in the lender’s favor, the appraiser would be threatened with non-payment, removal from appraiser panels, and/or blacklisted. If you haven’t read those blog posts, feel free to go back and have a look....

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...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

What Are You Waiting For? Only 179 Comments...Please Comment Now! 13

What Are You Waiting For?

Please comment now! VaCAP sent out a “Call to Action” a month ago to comment on the proposed increase in the appraisal threshold to $400,000. As of this writing, only 179 comments have been received. This is our future, please comment now! Comments must be received by February 5, 2019. 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...

Automated Loan Processing to End Appraisers... 2019 Big Battles Ahead 18

Big Battles Ahead for Appraisers

…complete elimination of appraisal as part of their fully automated loan processing objectives… Our work as appraisers & appraisal issue advocates is certainly cut out for us all in 2019. I think appraisal unity is going to be needed if we are all to take on the adverse issues affecting us. That includes AI. They still have a large number of honest, & competent members. I think the rest of us will have to let AI take care of AI issues. I’m not averse to butting heads with them on specific issues when necessary but alienating them rather than seeking...

Comments Needed for Proposed Rule to Amend Appraisal Requirements 8

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...

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