Tagged: FIRREA

Computershare 15 Minutes Appraisal Reviews & Cheap Diapers 10

Computershare Reviews & Cheap Diapers

The resulting “outcome” of those cheap diapers is the same outcome as Computershare 15-minute reviews must be… This didn’t start out as an article, but you know me. Doing research prior to posting in the 100% comments board I was shocked at how pervasive this new ‘service’ already is. A simple blog post can’t begin to cover it. Every single reader needs to research their own states requirements. The AMC at the following link makes this easy. Please look your state up. My concern was with Computershare and Colorado. Feel free to look them up by clicking here. If that doesn’t...

The FDIC Says NO to Appraisals - Appraiser Connections AMC Folds 10

FDIC Says NO to Appraisals

The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...

Sunshine Act - Federal Agencies Changing FIRREA & Raising De Minimis 5

Federal Agencies Changing FIRREA

VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraisal waivers in North Dakota. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies...

Appraisers Should Never Do Evaluations - Appraisers Blogs 15

Appraisers Should Never Do Evaluations

…users of evaluations knew & accepted that if they obtained evaluations in lieu of real appraisals that they were getting meaningless value opinions by unqualified personnel… TALCB will be considering the Board’s position regarding appraisers performing evaluations in compliance with USPAP at the next Board meeting on August 23, 2019 Dear Texas Appraisers Licensing & Certification Board Members: The short and sweet version is that appraisers should never, repeat never do ‘evaluations’. The term itself should never be uttered as if it refers to any legitimate appraisal product that meets the USPAP requirements of a real estate appraisal. When FIRREA...

Bill Requires AMC to Disclose their Fee and Fee Paid to the Appraiser 12

Full Transparency in Fee Disclosure

Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the appraiser by the AMC… HB 3619 has been referred to the House Financial Services Committee. VaCAP has learned over the weekend that HB 3619 has been introduced in the US House of Representatives. HB 3619, short titled “Appraisal Reform Act of 2019” amends the Financial Institutions Reform, Recovery and Enforcement Act. The main change to  FIRREA deals with appraisal management company and appraiser trainee registries and the addition of a member of the Veterans Affairs on the Appraisal Subcommittee. The bill also modifies Section 2603,...

The Role of Formal Valuations in the Home-buying Process is Under Attack 9

The Network Speaks Out

VaCAP and 27 other State Appraisal Organizations reached out to the House Finance Services Committee concerning the upcoming Subcommittee meeting entitled “What’s Your Home Worth? A Review of the Appraisal Industry” on June 20th. The Network stresses the most qualified to testify on the appraisal profession is an appraiser. The letter also outlines some of the flaws, inconsistencies and realities of the effects of appraisal management companies and how the GSE’s current “appraisal modernization plan” is actually harmful to consumers, investors, lenders, the housing market and the economy as a whole. Fannie Mae’s own publications are being used as documentation. Hopefully the committee members ask the...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. http://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Special Interests Killing Consumer Property Value Protection 13

Killing Consumer Property Value Protection

Before the ink was dry on FIRREA 1989, special interests were snipping away at it. Originally proposed field review requirements in FIRREA drafts for 1 in 10 appraisals would have made the Great Recession (TARP) impossible. Now those same interests are stripping away at the last vestiges of consumer and taxpayer property value protection. The formal appraisal. The MINIMUM level of protection that should be insisted upon. Dear Ms Kahng: My name is Mike Ford. I am Vice President – Special Projects; & Chairman of the American Guild of Appraisers National Appraiser Peer Review Committee; AGA#44, OPEIU, AFL-CIO. I am...

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...

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