Tagged: de minimis

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...

What If the Algorithms Are Wrong? Weapons of Math Destruction... 12

What If the Algorithms Are Wrong?

Algorithms are everywhere… “Algorithms decide who gets a loan, who gets a job interview, who gets insurance and much more — but they don’t automatically make things fair. Mathematician and data scientist Cathy O’Neil coined a term for algorithms that are secret, important and harmful: “weapons of math destruction.” Learn more about the hidden agendas behind the formulas.” “Algorithms are opinions embedded in code. It’s really different from what you think most people think of algorithms. They think algorithms are objective and true and scientific. That’s a marketing trick. It’s also a marketing trick to intimidate you with algorithms, to...

Should We Raise the Appraisal Deminimus Threshold to $2 Million? 7

Should We Raise the Deminimus to $2 Million?

Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF.  USPAP compliance is required for federally related transactions. USPAP comprises two parts:...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

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...

Hybrid Committee Meeting Recap 25

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 50

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...

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