Tagged: de minimis

Hybrid Committee Meeting Recap 13

Hybrid Committee Meeting Recap

The Recap The VREAB Committee meeting on hybrid appraisals met last week. The turnout was a decent one. Some traveled a great distance to attend. There were appraisers, assessors, consumers and trade group representatives in attendance. The meeting started with the Appraisal Foundation Video on Hybrid Appraisals. Public comments followed and many spoke and shared their concerns. Examples of hybrid appraisal products were submitted to the committee. Protecting the public was a key discussion and the following existing Virginia laws and regulations were discussed. 54.1-2009 Definition of appraisal- “Appraisal” means an analysis, opinion, or conclusion relating to the nature, quality,...

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...

Proposal to End Appraisal Requirement on Home Sales of $400k or Less 47

Proposal to End Appraisal Requirement

Regulators’ Proposal to End Appraisal Requirement on Some Home Sales of $400,000 and Below… The Federal Deposit Insurance Corp., the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve released a proposal that would increase the appraisal requirement from $250,000 to $400,000, meaning that certain home sales of $400,000 and below would no longer require an appraisal. According to data provided by the FDIC, the agencies estimate that increasing the appraisal threshold from $250,000 to $400,000 would have exempted an additional 214,000 residential mortgages at regulated institutions from the agencies’ appraisal requirement in...

Waiving Appraisals, Lowering Appraisal Standards, & Raising De Minimis... 13

Waiving Appraisals & Lowering Appraisal Standards

Freddie getting aggressive in waiving appraisals & promoting appraisal free mortgages… Appraisers, Yes, I have a ‘dog in the fight’ with this article, as I have been an Appraisal Institute member since 2003 (along with other association memberships since). But this article provides explanations about changes to the appraisal process I have not seen elsewhere. Excerpt from “Dodd-Frank rollback weakens appraisal standards“ They started to evaluate whether they wanted to raise that appraisal threshold level from $250,000 to some figure… They left it untouched at $250,000 for residential, but they have increased the commercial real estate appraisal threshold level just in the...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

Appraisal Thresholds Raised $500K. How Long Before Its Raised for SFR? 12

Appraisal Thresholds Bordello

Anyone wants to place a wager on how long before appraisal thresholds are raised for SFR? Retirement, with a part-time job working as a bouncer at a bordello in the Nevada desert is beginning to look appealing. Activity there is similar to what appraisers are experiencing these days. From the article: “The FDIC board of directors today (Mar. 20, 2018) approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000…” While the individual 1-4 unit investment properties are being kept at $250,000, would anyone like to place a wager on how long...

Appraisal Threshold on Commercial Loans May Change 4

Commercial Appraisal De Minimis Proposal

Proposal To Increase The Appraisal Threshold On Commercial Real Estate Loans The Federal Financial Institutions Examination Council’s Joint Report to Congress said the federal banking agencies are developing a proposal to increase the threshold for requiring an appraisal on commercial real estate loans from $250,000 to $400,000. The report did not propose changes to the current residential real estate threshold of $250,000. In addition, the agencies recognize that appraisals can provide protection to consumers by helping to assure the residential purchaser that the value of the property supports the mortgage amount assumed. Overall, the agencies believe that the interests of...

Residential Appraisers Being Phased Out 20

Appraisal Alternatives

Computers eliminating “boots on the ground” residential appraisers. An historian once quipped, “I cannot predict the future, but give me six months and I’ll tell you why it was inevitable.” Residential appraisers who work in the mortgage arena began to experience the sea change when UAD arrived amongst much fanfare in September of 2011. Years of portals, hard-stops, and overrides have settled into an uneasy routine. We’ve already seen changes to closing docs as a result of TRID (TILA RESPA Integrated Disclosures). That adventure began in November 2013. Washington DC, never content to maintain any level of consistency has already...

Appraiser Shortage Myth Used to Raise De Minimis Value 42

Appraiser Shortage Myth Used to Raise De Minimis Value

Appraisers, I know everyone is busy right now, but this cannot wait. This may be the most important blog post affecting appraisers this year. I don’t think it is an exaggeration to say that if something is not done, it really COULD lead to the end of ALL residential appraisers for federally regulated transactions under $500,001. FFIEC under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), is considering raising the de minimis lending level from $250,000 to $500,000, because the local community banks are complaining that they cannot find enough appraisers in rural America to handle the volume! If...

Raising Appraisal Threshold Levels 9

Raising Appraisal Threshold Levels

Adjusting appraisal threshold levels On December 2, 2015, Dave Towne called attention to an article on a potential increase in appraisal threshold levels, which appeared in the ABA Banking Journal. Excerpt: The banking agencies are revisiting the dollar thresholds for their appraisal requirements, FDIC Chairman Martin Gruenberg said in Arlington, Va., today at the final outreach meeting for the decennial Economic Growth and Regulatory Paperwork Reduction Act review. “Based largely on comments we have received during these outreach sessions, we have formed an define working group to review the appropriateness of dollar thresholds for transactions requiring appraisals and other requirements...

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