Tagged: Dodd Frank

Modernizing Appraisals: It seems we're stuck in 1989. 46

Modernizing Appraisals & Being Stuck in 1989

Modernizing Appraisals: It seems we’re stuck in 1989… On November 16, 2016, the Housing and Insurance Subcommitte held a hearing on “Modernizing Appraisals: A Regulatory Review and the Future of the Industry.” Subcommittee discussed modernizing appraisals to benefit American consumers. The hearing focused on necessary changes to the appraisal industry. Subcommittee Chairman Blaine Luetkemeyer (R-MO) explained: “Appraisals are one of the cornerstones of the home-buying process. Issues that impact appraisers also impact nearly every American buying or selling a home, in rural and urban areas; in high- and low-income neighborhoods. Yet when it comes to the regulatory regime surrounding appraisals,...

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 33

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

Earthworm AMCs and Free Appraisals 11

Earthworm AMCs and Free Appraisals

Quit working for the earthworm AMCs I love reading Jonathan Miller’s Housing Notes blog each week. Here is one of his entries from last week. Below this I’ll add my own $0.02. Actually, it’s worth a nickel! Let’s explore the concept of free appraisals. The idea that “you get what you pay for” doesn’t seem to apply to real estate. Appraisers have been under siege for the past decade and the industry is decimated. There are only a few good appraisers left in each market as lenders and the Appraisal Management Companies (AMCs) they use have pressed hard to convert...

Appraiser Safety - Stalked by Homeowner 29

Appraiser Safety, Stalked by Homeowner

Personal safety of appraisers I have several issues that focus on PERSONAL SAFETY of appraisers especially female appraisers that I need to address. I had a recent event where a homeowner was not happy with the appraised value of his home. Four weeks after I had turned in the appraisal, the lender, Freedom Mortgage, proceeded to send five sales that were 16 to 29 months old, for my review. I responded via StreetLinks AMC communication log stating these were not within FNMA guidelines. A few weeks later StreetLinks sent me the following: Good afternoon, the lender has ordered a second...

Lesson learned or Lessons Lost 12

Haven’t We Learned Our Lesson?

Lesson Learned or Lessons Lost? Many have heard me say that we should expect a large market correction around 2019-2020. Some agree, some think it will be sooner, and I am sure there are some that don’t think it will happen again because we learned our lesson. There are a ton of factors that drive it so it’s not an easy thing to predict. The good news is most agree that there will be one, we just don’t know when. We have not learned our lesson and the lesson will be repeated. I’ll share my 2 cents on this and...

Non-USPAP states - appraisers liability limited to appraisal fee 6

Limiting Appraiser Liability to the Cost of the Appraisal?

I recently got an email from an appraiser I have high regards for. He asked me a simple question that got me thinking. It was: “Why don’t a group of appraisers get together and form an AMC?” I found that an interesting concept. It has been done. Coester was an appraiser and now he is just an AMC. Allen Hummel, an Appraisal Institute icon, has an AMC. Why not? We know it better than anyone. But the devil is in the details. Appraiser’s liability for mistakes or omissions in this appraisal report is limited to a refund of the fee...

5

Simply too BIG to Say No to…

If they can’t even get their own PACE Pro form right, how are these alternative “valuation” providers going to get something as complicated as the value right? First American, and to some extent similar large scale conglomerate “players”, supply everything to the transaction: from the Home Warranty for the buyer, to the escrow services, to the mortgage company, to the mortgage servicer, to the title company, to the appraisal management company, to the appraiser panelists, to the software company that DESIGNS the software used for PACE Pro and almost all other appraisal software (ACI), to the BPO providers, to the...

AMCs vs Public Interest - VaCAP Advocacy 21

AMC vs Public Interest – VaCAP Advocacy

Since the beginning, Federal Regulation of the industry was initiated to “protect the public. “ FIRREA, USPAP, HVCC, Dodd Frank and state licensing of appraisers and appraisal management companies were initiated with consumer protection as the goal. Customary and reasonable fees, mandated by Dodd Frank, are also to protect the consumer. The Virginia Coalition of Appraiser Professionals supports customary and reasonable fees and believes in order to determine a customary and reasonable fee all things associated must be considered and incorporated into the determination. The below practices by AMC’s are not in the interest of protecting public trust and go...

Day Laborers Needed...Inquire at any AMC 6

Day Laborers Needed…Inquire at any AMC

Help Wanted – Day Laborers Needed …. Inquire at any AMC The Dodd Frank act requires the lender to be responsible for their agents. This means the lender is responsible for the actions of the AMC. Do the lenders know what their AMC’S are doing? Probably not. The Dodd Frank act also requires the most qualified appraiser be selected for each and every assignment. What vetting is done by the AMC’S to ensure the most qualified Appraiser is selected? Many AMC’S have the false mentality every appraiser is qualified and competent to appraise every piece of real estate. This simply...

VaCap Speaking out Regarding C&R Fees 8

VaCap Speaking out Regarding C&R Fees

CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs. AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession. In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement.   First, the Feds have made it very clear that lenders...

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