Tagged: C&R

Appraisal news for real estate appraisers and real estate professionals regarding Customary and Reasonable appraisal fees. News relating to the Appraisal Industry.

Non Payment to Appraisers by Diligent Asset Valuations - BREA vs DAV 8

Anatomy of a Substantiated (AMC) Complaint 

Diligent Asset Valuations Alleged Multiple Non Payment to Appraisers Anyone that knows me, or who has read past comments concerning California BREA’s non enforcement of C&R fees also knows I’m not generally their (BREA) biggest fan. However, it would be intellectually dishonest not to recognize a case where they did the right thing. The case in question, BREA vs Diligent Asset Valuations (DAV), involved alleged multiple order non payment to appraisers by an AMC where orders were placed or assigned through the MERCURY NETWORK. The specific logistics of how Mercury is involved could be of interest to those that use...

FTC Attorney Response & AGA Seeking Appraisers Opinions 9

FTC Attorneys Response to AGA

Is the FTC asserting that FNMA is exempt from antitrust laws? I don’t think of myself as being obtuse, nor do I think those that know me well would consider me to be particularly slow of wit or comprehension. Despite this, I’m truly confused by the Federal Trade Commission (FTC) attorneys response to the American Guild of Appraiser (AGA) email letter we sent them. The first sentence states “The federal antitrust laws prohibit anticompetitive mergers and business practices that seek to prevent hard-driving competition, such as monopolistic conduct, attempts to monopolize, and conspiracies and combinations that harm competition and consumers.”...

Suppression of Appraisal Service Free Trade & Fair Price Competition 23

Restraint of Trade Investigation

I am heartened that the Federal Trade Commission has recognized the need to assure that appraisal “…consumers deserve to benefit from a free market where those fees are set by competition.” It appears that your complaint may have been instigated by the very special interests that are most responsible for suppression of appraisal service free trade and fair price competition in America today. By that I am referring to the entities broadly described as Appraisal Management Companies (AMCs), and in this specific complaint – the Federal National Mortgage Association, also known as Fannie Mae and/or FNMA .

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...

VREAB board meeting - VaCAP Call to Action 34

Call to Action

Board meeting about AMCs hiring staff appraisers, email blasting, non C&R fees, & background checks. VaCAP understands you are busy with lots of orders, but it is important for you to attend the VREAB Board Meeting on Tuesday April 26th. There will be a public comment period during the meeting. Every independent fee appraiser needs to voice concerns about AMCs hiring staff appraisers to complete appraisals, email blasting, the continuation of non customary and reasonable fees, and background checks. The public is not protected with any of these practices. The Virginia Real Estate Appraisers Board Meeting April 26th,@ 10:00 AM...

Where is all the mortgage work 14

Where is all the Mortgage Work?

We should be busting with mortgage work. Where is all the mortgage work? I talk to appraisers and they all ask the same question. With the looming spring market and low interest rates, we should be busting with mortgage work. But the appraisers I know tend to get a reasonable and customary fee of above $400. So is it going to the bottom third? Now don’t get me wrong; I am quoting 2 to 3 weeks due to our back log. But outside of VA’s it’s everything but first mortgage work. I am fine with it because it’s less hassle....

Porter Ranch Environmental Issues 5

Environmental Issues Notice to Appraisers

Response to LRES email concerning appraiser’s responsibility regarding environmental issues Fellow Appraisers, Have you asked yourself WHY a few more of the larger regional AMCs are joining organizations like REVAA? In my opinion, it is because they and their clients (usually GSE lenders) KNOW that they are not truly compliant with Dodd-Frank’s C&R requirement. Despite disclaimers or advisories like this, they also know that the bulk of their work products are ‘probably not compliant’ with USPAP. Notices like this don’t normally get set out until ‘after the fact’ issues arise. REVAA recently helped coerce the State of Virginia (through threat...

Board Member Says Squeaky Wheel Gets the Grease 2

Board Member Says ‘Squeaky Wheel Gets the Grease’

Board Members reported a shortage of individual appraisers offering suggestions, complaints and concerns… Legitimate ‘complaints’ should never be referred to as whining by any professional in my opinion. To do so diminishes the importance of the concerns being addressed. I attended the Las Vegas Public Hearing of the The Appraisal Foundation (TAF) / Appraisal Practices Board (APB) last Friday. No Appraisers Guild or member funds were used in any way for this. There was lots of good information. Board Members reported that there really is a shortage of individual appraisers offering suggestions, complaints and concerns to them as a Board,...

Competition & Joe Above-Average 16

Competition & Joe Above-Average

The appraisal profession is in competition with other professions Ask any appraiser nowadays, and they can give you numerous details and opinions about why things are a mess and why appraisers are leaving this profession in droves. In a previous story, it was reported that Illinois alone lost somewhere near 900 appraisers last renewal. Every appraiser already knows about the fee problem, insane liability, higher costs, ridiculous revision requests, and the list goes on. All those reasons are the finer details. I would like to add a different perspective and paint a bigger picture as to why I think appraisers...

VaCap Speaking out Regarding C&R Fees 8

VaCap Speaking out Regarding C&R Fees

CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs. AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession. In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement.   First, the Feds have made it very clear that lenders...

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