Tagged: Dodd Frank

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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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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Call to Action in Support 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...

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