Tagged: FIRREA

Score Card, Turn Times, Undue Pressure & Appraisal Independence 16

Appraisal Independence

Most appraisers could care less about an amc score card… Professionals don’t treat other professionals like they are in grade school… What exactly is appraisal independence? Dodd Frank requires appraisal independence and associates it with pressure against the value of the property. But what about other areas of the appraisal process in which appraisers receive pressure? Let’s take turn times for example. Normal turn times in a steady market average 5-7 business days in most markets. Market activity, location, complexity, etc. will require longer turn times. First let’s define a business day. This is Monday through Friday and excludes Federal...

Protecting Appraisers Against Frivolous & Retaliatory 3rd Party Lawsuits 6

Frivolous & Retaliatory 3rd Party Lawsuits

Appraisers are routinely coerced & intimidated by third parties to violate their independence and integrity… Honorable Committee Members: We are writing to add our voice to that of the Massachusetts Board of Real Estate Appraisers (MBREA is a State Coalition of professional real estate appraisers) in support of each of the above bills. The American Guild of Appraisers is a Guild within the Office Professional Employees International Union (OPEIU) of the AFL-CIO, representing the appraisal and real estate related financial consumer / taxpayer interests of over twelve and a half million AFL-CIO Family Union & Guild Members; their families, retirees...

Unintended Users Phony Low Value Claims Against Innocent Appraisers 6

Phony Low-Value Complaints

ALL unintended users are specifically excluded from any right of reliance on this appraisal report… Recently, Mr. Steve Kahane, Board Member of the Association of Texas Appraisers (ATA) wrote a great article in WorkingRE. It included several suggestions for Texas to deal with it’s excessive number (70%-75%) of unfounded complaints against appraisers. An American Guild of Appraisers member in New Jersey who has twice faced this exact kind of complaint abuse reminded me of the article and concurred with its suggestions for his state. Fortunately for our member, New Jersey is not one of those relatively few ‘charge and win...

Another Huckster Enters the Appraisal Arena 20

Another Huckster Enters the Appraisal Arena

Yet another third party huckster has entered into the real estate appraiser and appraisal arena. It’s that time again! Yet another third party huckster has entered into the real estate appraiser and appraisal arena. Apparently motivated by pure altruism. We identified a need in the marketplace to address a common problem that lenders are regularly challenged with in providing accurate appraisal quotes and then ensuring pricing on the Loan Estimate is consistent and compliant,” stated Vladimir Bien-Aime, president and CEO at Global DMS. (I LOVE this guy, he writes like me!) Global DMS Launches SnapVal to Provide Instant, Accurate, Guaranteed...

Increased Regulatory Persecution of Real Estate Appraisers - USPAP 20

Increased Regulatory Persecution of Appraisers

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

Open Letter to Taxpayers... Afterall, Taxpayers Aren’t Stupid 32

Open Letter to Taxpayers

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

No Numerical Shortage of Appraisers in North Dakota - AppraisersBlogs 11

Nonexistent Shortage of Appraisers

…there is a shortage of appraisers willing to work for sub-par fees and unrealistic turn around times… The American Guild of Appraisers has already heard from many of our North Dakota and nearby states members on the above request. The most recurrent complaint is that there is no numerical shortage of appraisers in North Dakota (approximately 300+-) as well as adjacent states appraisers that regularly cross over to serve client needs there (another 30 to 40+-). What I am told is that there is a shortage of appraisers willing to work for sub-par fees and unrealistic turn around times! There...

How Many Appraisers Are in North Dakota? - Appraisal Shortage Saga Lingers 43

How Many Appraisers Are in North Dakota?

The answer is 153, who are individually licensed in North Dakota. I didn’t segregate the three different license types. This figure came from a download of the ASC appraisal registry of ND licensed appraisers, and not counting duplicate name appraisers with multiple licenses in other states. Many of these appraisers are ‘dual licensed’ in more than one state, in most cases immediately adjacent, but sometimes in states far distant from ND. What’s the population of North Dakota? According to Wikipedia: The United States Census Bureau estimates North Dakota’s population was 755,393 on July 1, 2017, a 12.3% increase since the 2010 United...

Push for Automated Appraisals... Even Paranoid You Can Have Enemies 16

Just Because You’re Paranoid Doesn’t Mean They Aren’t After You

It appears the government sees the future of appraising as one driven largely by Automated Valuation Models, Hybrids, and outright appraisal waivers…. The title for this article comes from a famous quote by Joseph Heller (the author of Catch-22 fame). I thought of his pithy quote when reading the recommendations by the Department of Treasury to the president. The title of the report: “A Financial System That Creates Economic Opportunities Nonbank Financials, Fintech, and Innovation” seems innocuous enough. However, some decidedly non-innocuous observations / recommendations regarding the appraisal industry appear starting on page 103. The report starts off promising enough;...

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