Tagged: Dodd-Frank Act

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Twisted AMC & C&R Fees Gone Wrong!

This AMC is Just Wrong & Confused! An AMC sent an appraiser the following email this morning: “…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“ Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the...

Transparency… Where is it? 38

Transparency… Where is it?

Is transparency with the lender? Did the lender explain to the borrower the fee they (the borrower) are paying to the AMC and the benefit they are receiving? Oh wait, what benefit is the AMC to the borrower? Was this fee disclosed verbally, in writing or anywhere? Did the lender disclose any relationship they have with the AMC? Is transparency with the AMC? Did the AMC disclose their fee to the borrower? Did the AMC disclose how much the appraiser is being paid? Did the AMC explain any benefit of their service to the borrower? Did the AMC explain how...

AMC Regulation Rule Finally Published in the Federal Register - Imagecredit Flickr - Steven Lilley 1

Federal Register: AMC Final Rule

AMC Regulation Rule Finally Published in the Federal Register Appraisers and others, On June 9, 2015, the Federal Register published the new AMC Registration and Regulation Final Rule: The OCC, Board, FDIC, NCUA, Bureau, and FHFA (collectively, the Agencies) are adopting a final rule to implement the minimum requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) to be applied by participating States in the registration and supervision of appraisal management companies (AMCs). Thanks to Bill Garber, Appraisal Institute Director of Governmental Affairs, for sending me this info today. I first wrote & sent info...

1st Enforcement of C&R Fee Provision Louisiana Makes History - Imagecredit Flickr - Roland Tanglao 5

Louisiana Makes History – C&R Fee

First Enforcement of C&R Fee Provision: Louisiana Makes History Nearly five years after Dodd-Frank set forth rules regarding Customary & Reasonable fees (C&R) for appraisers, an agreement last week between a state board and an Appraisal Management Company (AMC) is the first evidence of enforcement. The bottom line for appraisers is that they may be finally on their way back to customary and reasonable fees. On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) issued a Stipulations and Order Memorandum (SOM) wherein Coester Appraisal Management Group, also known as Coester VMS, offers no admission of guilt but agrees...

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Evolution of C&R fees – Alter Your Thinking

Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...

Appraiser Background Check Requirements 9

Appraiser Background Check Requirements

The info below from AI’s Appraiser News OnLine is about the action taken by the AQB at their recent meeting in Seattle, WA, which I was unable to attend. It’s still unclear if “existing license holders” must undergo a background check at the time of their license renewal. Apparently that’s determined by individual states. And it’s still difficult to get all the multiple clients appraisers deal with, to accept “one” background check performed in a state or by a separate organization. So appraisers are sometimes faced with having to spend money to provide different background checks to individual clients. Frankly,...

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AMCs to Pay Appraisers C&R Fees

Call to Action in Support of Virginia Senate Bill Requiring AMCs to Pay Appraisers C&R Fees Appraiser Colleagues, Finally, you have an opportunity to get what you have been screaming for: customary and reasonable fees for your work. On January 23, 2015, Senator Martin offered Senate Bill NO. 1445, requiring appraisal management companies to pay appraisers customary and reasonable fees. The bill mirrors the language in Dodd-Frank. A copy of SB 1445 as introduced is attached. Please contact your legislative representatives in support of this important legislation. VAR’s support will be important to the success of this bill. Please include VAR...

Fannie Mae Claims the CU Process Will Improve Appraisals 5

CU Process Will Improve Appraisals? A Pipedream or Reality?

Fannie Mae Claims the CU Process Will “Improve Appraisals.” A Pipedream or Reality? Appraisers, A few days ago, I watched the FNMA eLearning webinar “Introduction to CU” video showing how their new Collateral Underwriter will be implemented, starting on Jan. 26, 2015, applying to 1004 and 1073 Reports (initially). You really should watch this also!  CU applies to FANNIE MAE only; FreddieMac, VA, FHA, USDA are not involved at this time. Click this link, and you’ll find the link to the video ½ way down on the left. I captured a few screen shots of their presentation to help explain...

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Working for an AMC? How Exciting!

Can You Tell I’m Excited about working for an Appraisal Management Company? Today I received a notice telling me my best customer was changing over to an AMC for all their appraisal ordering. I have worked for this company for many years and have always enjoyed a great relationship. Today that ended. I can longer talk to any person at the bank. In my application to continue working for this company I have worked with for so long, I have to provide sample reports, a resume, three business references, license info, info about CE classes I have taken. I have...

Virginia Study on Customary & Reasonable Fees for Residential Appraisals 1

Residential C&R Fees Study in Virginia

Virginia Study on Customary & Reasonable Fees for Residential Appraisals BLACKSBURG, Va., Oct. 7, 2014 – Virginia Tech researchers and students conducted a survey of Virginia residential real estate appraisers to analyze the patterns of fees earned in 2013. Prior to the release of this report, no data existed that defined “customary and reasonable” residential real estate appraisal fees in Virginia. This report is the third report of its type to be conducted in the United States, and the first in Virginia. The research was conducted in response to recent amendments to the Truth in Lending Act modified by the...

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