Tagged: FIRREA

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;...

MISMO Blueprint... The Evil Octopus - AppraisersBlogs 4

The Evil Octopus

Appraisers, it’s not paranoia when ‘the bastards’ really are out to get you (end us as a profession). …Find each octopus and how they relate to our jobs. Look at MISMO Directors list… An Open Letter to Appraisers: Residential & Commercial This started as a response to a blog post by a respected appraiser concerning the influence of AMCs. During drafting it was clear that trying to explain AMCs was only part of the bigger struggles we face today. Picture a violent “all in” three-way gang fight among Octopi. Say a dozen on each side. That’s 36 Octopi x 8 tentacles...

MISMO, Appraisal Data Mining, Hybrids, and Other Fraud Facilitators 16

Who’s to Blame?

Looking at who and what MISMO Directors are, is it a surprise that FNMA included language in basic appraisal forms resulting in appraisers having infinite liability and no ownership over their own work product IF they do work for FNMA?… European Union General Data Privacy Regulations (EU GDPR) may seem like a stretch for an Appraisers Blog topic, but please bear with me. For some time now, The Appraisal Foundation has been focusing on major international valuation issues other than real estate appraisals. IVSC is one of the bigger and most detrimental misdirection’s they’ve taken as far as impact on...

FHFA Working Paper Credibility Questioned by AGA 10

Working Paper Credibility Questioned

NO REAL ESTATE APPRAISER IN THE COUNTRY IS ALLOWED TO MISS THE MARK BY 7.8% WITHOUT RISKING LOSS OF LICENSE! The Working Paper demonstrates more than anything else, that given an 8-hour work day the computer will take 6 full working days (1.2 working weeks) to arrive at a result that is at best 7.8% error prone. Office of the Director, Honorable Melvin Watt Federal Housing Finance Agency… Dear Sir(s) The American Guild of Appraisers is a Guild within the more than 12 1/2 million members, retirees and family members of our parent union OPEIU, AFL/CIO. In addition to representing...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

xml sitemap