Tagged: de minimis

The FDIC Says NO to Appraisals - Appraiser Connections AMC Folds 2

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...

Committee Passes H.R. 3619 - Requires AMCs to Disclose their Fees 4

Committee Passes H.R. 3619

H.R. 3619 has passed out of committee and is now sitting in the US House for consideration. H.R.3619 would amend the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to provide the Appraisal Subcommittee with the authority to modify annual registry fees for appraisal management companies, to maintain a registry of trainees and charge a lower trainee registry fee, and to allow grants to States to assist appraiser and potential appraiser compliance with the Real Property Appraiser Qualification Criteria and would require AMCs to disclose their fees. The NCUA Quadrupled The Appraisal Threshold For Nonresidential Real Estate Loans By a 2-1...

NCUA Board Decision Could Potentially Hurt Commercial Appraisers 8

NCUA Quadruples the Appraisal Threshold

Like so many things in life, the NCUA Board decision was predicated primarily on greed… This is a lot like the liar loans that infiltrated residential lending not that long ago. Appraisers, especially Commercial appraisers, I picked this info up from a message sent out by the Appraisal Institute on July 18, 2019: “The NCUA Board of Directors today quadrupled – from $250,000 to $1 million – the appraisal threshold for nonresidential real estate loans. NCUA is the National Credit Union Administration. The appraisal threshold is the loan amount below which appraisals are not required. Increasing the threshold would drastically...

North Dakota Appraisal Waiver Granted 8

North Dakota Appraisal Waiver Granted

News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...

Commercial Appraisers Livelihood Threatened by NCUA 6

Commercial Appraisers Livelihood Threatened

Commercial appraisers may want to open this link, and read it. Your livelihood is possibly threatened by the National Credit Union Administration (NCUA). You may want to send a letter to the NCUA Board of Directors. Proposed Appraisal Rule Provides Relief, Clarity As part of the NCUA’s regulatory relief agenda, the Board approved a proposed rule (Part 722) to amend the agency’s real estate appraisal requirements for certain transactions. The proposed rule would provide a measure of regulatory relief and increased clarity by: Increasing the threshold for required appraisals in non-residential real estate transactions from the current $250,000 to $1 million; Reorganizing...

Appraisers Disappointed at Federal Banking Agencies - Appraisers Blogs 21

Appraisers Disappointed at Federal Agencies

I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. We knew that when we joined with others in signing the letter. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy...

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...

Appraisals Costs Hardly a Burdensome Cost? Appraisers & Realtors Unite! 19

Standing With Us Protecting Consumers!

…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...

MCS Valuations (AMC) Closing Shop - ABA Supports Raising De Minimus 18

MCS Valuations (AMC) Closing Shop

I saw a posting by another appraiser on a Facebook page on February 5, 2019 that MCS Valuations, based in Lewisville, TX, is closing shop. They are an AMC, and provide BPO’s and other real estate related services. The appraiser posted a letter from the company. They will not be placing any more appraisal assignments, but are asking appraisers to finish any assigned reports already in the pipeline. What’s really striking about this closure is that in 2014, MCS Valuations bought ‘components’ of CoreLogic’s associated entities that CoreLogic no longer wanted in their business! February 5, 2019 This communication is to inform...

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