Tagged: Dodd Frank

Appraisal news for real estate appraisers and real estate professionals regarding the Dodd–Frank Wall Street Reform and Consumer Protection Act. News relating to the Appraisal Industry.

Evaluation NOT required to Meet USPAP - AGA Views on Legislative Bills 17

The Devil is Always in The Details

An evaluation is NOT required to meet USPAP requirements… I went over the bills VaCAP requested action on (see VaCAP Legislative Call to Action) and wanted to share my views as it appears they were interested in individual views. HB 1453 Real estate appraisers; changes definition of evaluations. Introduced by: R. Lee Ware SUMMARY AS INTRODUCED: Real estate appraisers; evaluations. Changes the definition of "evaluation" from an analysis, opinion, or conclusion relating to the nature, quality, value, or utility of specified interests in, or aspects of, identified real property to an opinion of the market value of real property or real...

Reconsideration of Value Requests & Undue Influence on Appraisers 20

Reconsideration of Value Requests

Open invitation for spurious reconsideration requests… No thank you. I just checked your website and glanced at your “clients” tab, Reconsideration request form. It pretty well negates all the puffed up hyperbole in your email invitation. It is people like you that are the problem, not solutions. Do you think a one of two items drop down menu is an adequate reason for asking an appraiser to reconsider their value? Do you not see a need to request a full and thorough explanation as to why your clients might be asking for a reconsideration? At a minimum didn’t you feel...

Valuation Partners & Schizophrenic AMCs vs. Appraisal Professionalism 20

FTC & REVP vs LREAB Bombshell

Like many other appraisers I received a copy of paperwork filed in conjunction with the Louisiana Real Estate Appraisers Board / FTC and Real Estate Valuation Partners (REVP) aka Valuation Partners. (Thank you VaCAP!) To me it’s a bombshell, but before I go into the story of who did what to whom, and for how much let’s start off by asking all readers to click this link to see who the players are. Even if you read the article elsewhere please read the following link. Got it? Great. Just so we are clear, one of the Chief players appears to...

Blast AMCs Emails Do Not Meet the Spirit of The Law 16

What Goes On Behind The Scenes…

This year it appears many AMCs have turned to blast requests of fee and turn time. We get them constantly and simply delete them. Last week we received a blast email from an AMC that sends out blast requests for bids. We have never worked with Appraisal Nation before and don’t know how we ended up on their panel. In their rush shopping for the cheapest and fastest appraisers, they forgot to BCC the appraisers they blasted. It appears that this AMC is not only incapable of maintaining quality control and assuring competency for specific assignments but by disclosing appraisers’...

Request for Appraisal Waivers If Granted Will Erode Public Trust 68

Appraisal Waivers vs. Public Trust

If the ASC grants the request for appraisal waivers, the precedent will have been set for other banks to follow… TriStar Bank has requested appraisal waivers for the entire year of 2018. According to the bank, they are having difficulty getting appraisals in the Nashville area and there is only one Certified General Appraiser in the the locality in which they are headquartered. Below is an excerpt form their letter to the ASC. They offer options in lieu of appraisals: Obtain an estimated value from a Realtor, selected from a small group of trusted Realtors who are not involved in...

Increasing use of AMS to replace AMCs 15

Increasing use of AMS to replace AMCs

AMS on fast track to replace AMCs… Well, it looks like the detritus of HVCC has finally come full circle. AMS (services vs companies) are on the fast track to replace AMCs. AMCs that foster their use haven’t realized that yet. They have given the lenders the tools needed to avoid costly appraisal management oversight departments while at the same time giving them the ability to use only those appraisers willing to make the deals work. They mistakenly believe that by delegating to an AMS or AMC they have met their due diligence requirements.Quality control? Sure. Just ignore the FNMA...

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What Can You Do When AMC Does Not Pay?

What happens when an AMC does not pay or closes its doors & should funds collected for appraisals be kept in escrow? 54.1-2021.1 of the Code of Virginia requires AMCs to post a $100,000 bond or letter of credit. Appraisers may be able to file a claim against the bond or letter of credit and receive funds if they have not been paid. Directly from the statute: “§ 54.1-2021.1. Appraisal management companies; license required; posting of bond or letter of credit. In addition to the filing fee, each applicant for licensure shall post either a bond or a letter of credit...

Pressure Can Never Be Removed From Appraisers 5

Gaining Perspective On Our Profession

Pressure that used to be overt has now become covert… I hold no particular pedigree or credential to speak for everyone in the real estate appraisal profession. All I can do is draw from nearly 26 years of being a part of it. In that time, I have heard almost every opinion on every issue that promises to be the next big challenge for our industry. It’s true that like everything, change is inevitable. We adapt to new technologies and practices as well as learn new skill sets. From FIRREA to Dodd-Frank, appraisers have continued to evolve when swift moving...

Allegations of Price Fixing by FTC Against LREAB: Response Filed 17

Allegations of Price Fixing Rejected by LREAB

LREAB denies FTC’s allegations as factually false & politically wrong-headed… On June 19, 2017, the Louisiana Real Estate Appraisers Board (LREAB) filed a response to the Federal Trade Commission’s price-fixing allegations. In its 15-page response, LREAB denies all FTC’s allegations (see PDF at the end of the article). GENERAL RESPONSE TO THE COMMISSION’S ALLEGATIONS To shore up the integrity of the residential mortgage appraisal process and, thereby, help to avert a recurrence of the real estate-fueled financial crisis of 2007-2009, the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires States to empower their real estate licensing agency,...

FTC Attorney Response & AGA Seeking Appraisers Opinions 9

FTC Attorneys Response to AGA

Is the FTC asserting that FNMA is exempt from antitrust laws? I don’t think of myself as being obtuse, nor do I think those that know me well would consider me to be particularly slow of wit or comprehension. Despite this, I’m truly confused by the Federal Trade Commission (FTC) attorneys response to the American Guild of Appraiser (AGA) email letter we sent them. The first sentence states “The federal antitrust laws prohibit anticompetitive mergers and business practices that seek to prevent hard-driving competition, such as monopolistic conduct, attempts to monopolize, and conspiracies and combinations that harm competition and consumers.”...

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