Tagged: de minimis

Reconciling the Erosion Within My Profession... Preserving the Public Trust 12

Reconciling the Erosion Within My Profession

The continued reliance of unregulated aggregators and bifurcated products continues to erode the public trust at the expense of discarding the profession specifically intended to promote the public trust. How does this protect the public?… On June 14, 2005 Steve Jobs told a class of graduates, “you can’t connect the dots looking forward; you can only connect them looking backward” Around the same time, I was appointed as the sole residential member of the appraisal licensing board of my state. Little did I realize that this 2005 governor-appointed position would eventually lead me to sharing a stage in 2018 with...

FIRREA Under Attack - Protecting Homeowners from Appraisal Loopholes 25

FIRREA Under Attack!

…the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for which an appraisal is required… Congresswoman Maxine Waters and Congressman William Lacy Clay request a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. The letter to  Gene Dodaro, Comptroller General, Government Accountability Office, addresses threshold increases, regulatory exemptions, appraisal waivers, the North Dakota appraiser certification waiver and evaluations in lieu of an appraisal. It is clear the Chairwoman of the House Financial Services Committee and Subcommittee Chairman on Housing, Community Development and Insurance...

Low Mortgage Rates and Plentiful Appraisal Waivers - Appraisers Blogs 9

Low Rates and Plentiful Appraisal Waivers

The graph below comes from Len Kiefer, the data guru at Freddie Mac. Are we due for even lower rates? Who knows. But they have been lower not long ago. Theoretically, appraisers should have been really busy since about November 2018 through this past year. Were you? Me, not so much, but I don’t work for many AMC’s either. The fact that the GSEs and others have diminished the value of getting an appraisal done has adversely impacted our work. Waivers are plentiful now, and the raising of the de minimus threshold to $400K for non-GSE loans has reduced the...

Loans Affected by the $400,000 Appraisal Threshold Increase 2

Loans Affected by the De Minimus Increase

NCUA is advocating for an increase in the de minimus to $400K for loans provided by Credit Unions… The $400,000 de minimus is now ‘official’ but it doesn’t apply to most appraisals. Here’s an article from HousingWire, published on 10/8/2019, which correctly states when this change took effect, which you should read. From the article: Now, it’s important to note that the new rules do not apply to loans wholly or partially insured or guaranteed by, or eligible for sale to, a government agency or government-sponsored agency. What that means is that loans sold to or guaranteed by the Federal...

Appraisal Waiver Questioned by Legislators- Asking ASC for Justification 8

Appraisal Waiver Questioned by Legislators

Late Friday afternoon, VaCAP learned the Financial Services Committee Chairwomen. Maxine Waters and Senator Sherrod Brown, Ranking Member of the Senate Committee on Banking Housing and Urban Affairs, sent a letter to the Appraisal Subcommittee Chairman Arthur Lindo inquiring around the circumstances of the North Dakota Appraisal Waiver that was granted a few months back. The exact verbiage used in the letter to describe the waiver was “unprecedented with minimal justification.” This speaks volumes as to their concern. Congress has repeatedly recognized the essential role that appraisals play in both safety and soundness and consumer protection. That is why it is...

War on the Appraisal Industry. Another Great Real Estate Depression 11

The Collective Rot

Over 11,000 appraisers signed that petition… The US Congress completely ignored it and, as a result, The Great Real Estate Depression followed. Déjà vu: Or is it Déjà Poo (I’ve heard this crap before)? The Collective Rot Growing Within the Shadows of the Great Real Estate Depression We are just 11 years past the beginning of the Great Recession. Some estimate the US suffered a $14 trillion loss in wealth. Others estimated the loss as high as $21 trillion. This event is more commonly referred to as The Great Real Estate Depression by those of us who are or were in the real estate industry...

Evaluations Concept Paper, Bringing Evaluations Under USPAP Umbrella 4

Bringing Evaluations Under USPAP’s Umbrella

Evaluations: Concept Paper, Webinar, Public Meeting In early August, The Appraisal Foundation announced that the The Appraisal Standards Board would be considering adopting standards for evaluations in the Uniform Standards of Professional Appraisal Practice (USPAP). On September 3, 2019, they announced three opportunities to learn more and share your insights. Concept Paper The Appraisal Standards Board is seeking your feedback on the concept of developing standards for performing evaluations in USPAP. Submit your comments to ASBcomments@appraisalfoundation.org. The comment period closes on October 11, 2019. Read the evaluations concept paper here Webinar Wayne Miller, chair of the Appraisal Standards Board, and...

The Raising of the De Minimus and Its Impact on the Appraisal Industry 11

De Minimus Impact on the Appraisal Industry

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

The FDIC Says NO to Appraisals - Appraiser Connections AMC Folds 10

FDIC Says NO to Appraisals

The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...

Sunshine Act - Federal Agencies Changing FIRREA & Raising De Minimis 5

Federal Agencies Changing FIRREA

VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraisal waivers in North Dakota. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies...

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