Tagged: Consumer protection

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 37

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...

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...

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