Tagged: Dodd Frank

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...

FFIEC Requested Action on TRID - Imagecredit Flickr - Johannes Ahlmann 6

FFIEC Requested Action on TRID

The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...

AMC's “My Way or the Highway” Attitude 47

AMC’s “My Way or the Highway” Attitude

Apparent appraiser abuse by AMC’s… As Chairman of the American Guild of Appraisers (AGA) National Appraiser Peer Review Committee, I have had the opportunity to see and hear directly about many cases involving alleged, as well as apparent appraiser abuse by AMC’s. These cases ranged geographically from California, Arizona, Michigan, Illinois, Florida, North Carolina, Louisiana, New Jersey, Virginia, New York, Maryland, and District of Columbia. As a QC consultant to a smaller appraiser owned AMC, I have also seen low fee spreadsheets from a variety of lenders that had 90% listed at the SAME APPRAISER fees: $495.00 (which INCLUDED the AMC...

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Appraisal Fees ARE Being Manipulated

Gas prices in California were $4.25 to $4.50 when oil was last at $100 a barrel. A week ago they were $50+/- a barrel and our pump prices were still over $4.00 a gallon. We are told ‘environmental’ mandated blended methanol is the cause of the $1.30 higher pricing than anywhere else in the Continental US. When those environmental laws were being passed we were told they’d only add from $0.05 to MAX of $0.15 per gallon-NOT $1.30 or 43% more! We KNOW that California politicians have also very recently heavily increased gas taxes in their never ending war against internal combustion....

AMC Dangers: Appraisal Management Companies (AMC) are changing how our profession works 4

AMC Dangers to the Consumer

Appraisal Management Companies (AMC) are changing how our profession works. It’s important to know exactly how they are affecting the real estate process, especially if you are a home-owner, looking for real estate or are involved in another part of the property. Who does an Appraiser work for? An appraiser works for “The Client” named in the report who ultimately responsible for the appraiser’s compensation. It is important to realize that while a borrower may have paid a lender or third party the cost of the appraisal, “The client” remains the only party authorized to use the report. The appraiser...

Appraisers Participation Needed - NMAC Tackling BPO & CU Issues - Imagecredit Flickr - Miles Heller 2

Appraisers Participation Needed – Tackling BPO & CU Issues

The appraisal industry was blindsided once again only this time by the AG’s office when they determined that the Real Estate Appraiser Board cannot regulate BPO’s. The New Mexico Appraiser’s Coalition and the Rio Grande Chapter of the Appraisal Institute sent a joint letter to the Appraisal Board prior to a hearing that was held in January to discuss the BPO language in the Appraiser Act. Although we feel we provided enough information to guide the Board, the Attorney General Representative at the meeting made the determination that the Appraisal Board had no jurisdiction over the BPO product. Even though...

Appraiser-Client Relationship - Imagecredit Flickr - Dennis Hill 15

Don’t You Value our Relationship?

Relationships, we all have them.  And despite the efforts of Dodd Frank to destroy them, we have somehow managed to keep them. A big bank that I had a great relationship dropped me because their portal system decided there were too many appraisers last year and left me hanging. No orders for a year. Now they’re busy and want me to do appraisals. Great! But between the portal fees, underwriting charges, title surpluses, software charges, destination charges, taxes, etc. the fee works out to be substantially lower than most work I have. They asked me “don’t you value our relationship?”. I replied where...

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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