Tagged: FIRREA

Bill Requires AMC to Disclose their Fee and Fee Paid to the Appraiser 7

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...

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 21

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...

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