Tagged: Federal Reserve Board

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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...

Customary but NOT Reasonable Fees 28

Customary but NOT Reasonable Fees

REASONABLE needs to become the appraiser’s operative word Appraisers, It’s time to grow a pair as some people say, or to stiffen the backbone, and quit caving in to the low ball fees being offered by some in this crazy “industry.” Another true statement is “you are what you are worth”. If you, as an business person, only know how to say yes to low fees, you won’t be worth anything higher to the majority of clients. Further, your self image and actual net worth are negatively impacted. You cannot expect to earn a certain income, then wonder why you gave yourself...

Appraisal Exemptions Proposed Rule 1

Proposed Rule on HPML Appraisal Exemptions

Appraisal Exemptions: Agencies Issue Proposed Rule to Exempt Subset of Higher-Priced Mortgage Loans from Appraisal Requirements WASHINGTON— Six federal financial regulatory agencies today issued a proposed rule that would create exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans. The proposed exemptions are intended to save borrowers time and money and to promote the safety and soundness of creditors. The appraisal requirements for higher-priced mortgages were imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Under the Dodd-Frank Act, mortgage loans are considered to be higher-priced if they are secured by a consumer’s...

NAIHP Promotes New Appraisal Rules on Capitol Hill 4

NAIHP Promotes New Appraisal Rules on Capitol Hill

NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...

REVAA FAIR appraisal fees 18

REVAA and FAIR Approach for Appraisal Fees

REVAA and FAIR Call for Market-Driven Approach for Appraisal Fees Washington, DC (PRWEB) July 14, 2011, Donald Kelly, executive director, Real Estate Valuation Advocacy Association (REVAA)/strong>, appeared today before the House Financial Services Committee, Subcommittee on Insurance, Housing, and Community Opportunity to testify on behalf of REVAA and the Coalition to Facilitate Appraisal Integrity Reform (FAIR) on Mortgage Origination: The Impact of Recent Changes on Homeowners and Businesses. The testimony comes just prior to the Federal Reserve Board transitioning its rulemaking authority to the Consumer Financial Protection Bureau (CFPB). Members of REVAA and FAIR advocate that the Federal Reserve Board,...

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