Tagged: FIRREA

Baby or Bath Water? And Is it Time to Take Back USPAP? 31

Baby or Bath Water? And Is it Time to Take Back USPAP?

About half of AICPA members don’t believe in USPAP… When I first heard that “they” were trying to do away with the Appraisal Practices Board (APB) of the Appraisal Foundation (TAF), I tried to keep an open mind. I also wondered who “they” are. Did the Appraisal Institute (AI) finally get a sympathetic ear in Congress? Was it preemptive action by the Board of Trustees in anticipation of budget cuts by the new administration? By the way, what does the APB do? I certainly had it wrong. I thought they helped develop the Advisory Opinions (AOs)! To be candid the...

Eliminate the Appraisal Subcommittee too! Appraisal Institute Effort to Eliminate the ASC 38

AI’s Effort to Eliminate the ASC!

Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...

Appraisal Regulations - Life After Dodd-Frank ~ copyright AppraisersBlogs 5

Life After Dodd-Frank

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

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...

STOP the Idiotic Constant Parsing Changes in All Areas of USPAP 14

It’s Time to STOP the Foolishness

STOP the constant parsing changes in all areas of USPAP I encourage ALL appraisers in the DC Metro area to attend the upcoming ASB Public Meeting on October 21, 2016. In a nut shell, my strong belief is that they need to STOP the constant parsing changes in all areas of USPAP. NOT ONE of the proposed changes is a necessary change. NOT ONE! No wonder state regulators no longer comprehend USPAP! If they need the extra money that selling new versions of USPAP produces, then just CHARGE US DIRECTLY! The purpose of FIRREA was to preserve the public’s trust...

Serfs Are Starting to Get Upset 10

Serfs Are Starting to Get Upset

The serfs are PISSED! Apologies. America was not founded by people that ‘went along to get along’, or that were willing to accept economic or political serfdom. Though they did so until a critical mass of frustration was reached. It is human nature to seek and then protect the benefits of privilege. To some extent this is a positive attribute. It’s the foundation of Capitalism. It is only when dishonesty and manipulation of laws becomes prevalent that the system is at risk, and not operating properly. We had dueling to keep honorable people honorable two hundred years ago. That was...

AVMs can Never replace Appraisals 34

AVMs Can NEVER Replace Appraisals

AVMs Can NEVER Replace Appraisals & why FNMAs vaunted CU AVM is flawed! Yesterday (March 15, 2016), an appraiser called me to discuss a complex assignment he had. One of his comparable sales was reported in MLS as having sold for $3,469, 898. It was in range with his other comparable sales for his subject property. It was the most similar comparable property. When he went to verify the sale price with our Los Angeles, California subscription-equivalent to “public records” he discovered a shocking discrepancy he couldn’t explain. RealQuest (CoreLogic) showed the full value sale price as $17,665,455! So what...

Experience, Education Criteria Input Request & AGA Open Letter 18

AGA Open Letter Regarding Changes to the Criteria

Request for Appraiser Input The AGA sent the below letter to the AQB in response to their outreach asking for comments. Please write them and tell them YOUR views. If you agree with what we have said, then just copy it and add your name to it saying “we agree”. Or don’t copy it, and just say “We agree with the AGA letter”. If there are any significant parts you disagree with, then please ‘except’ those. If you have additional thoughts or suggestions for them (civil ones), feel free to add them. I’ve already received an acknowledgement so I KNOW...

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...

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

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