Tagged: FIRREA

TAF Admits Current USPAP Is Inadequate & Requires Substantial Change 11

TAF / ASB Challenge USPAP

30 days after implementation of the last changes, ASB/TAF is already admitting they think the current USPAP is inadequate and requires substantial change. They’re ALREADY Doing It Again! On January 30, 2018 the Appraisal Standards Board announced the release of their Discussion Draft for the 2020-2021 USPAP based in part on a survey from 2017 & prior draft comments. I’m confused. Didn’t we just have the 2018-2019 become effective 30 days ago? Should all those that have not yet purchased 2018-2019 just save their money and wait for the significantly revised 2020-2021 revisions? Rely on word of mouth and online...

Evaluation NOT required to Meet USPAP - AGA Views on Legislative Bills 17

The Devil is Always in The Details

An evaluation is NOT required to meet USPAP requirements… I went over the bills VaCAP requested action on (see VaCAP Legislative Call to Action) and wanted to share my views as it appears they were interested in individual views. HB 1453 Real estate appraisers; changes definition of evaluations. Introduced by: R. Lee Ware SUMMARY AS INTRODUCED: Real estate appraisers; evaluations. Changes the definition of "evaluation" from an analysis, opinion, or conclusion relating to the nature, quality, value, or utility of specified interests in, or aspects of, identified real property to an opinion of the market value of real property or real...

Increasing use of AMS to replace AMCs 15

Increasing use of AMS to replace AMCs

AMS on fast track to replace AMCs… Well, it looks like the detritus of HVCC has finally come full circle. AMS (services vs companies) are on the fast track to replace AMCs. AMCs that foster their use haven’t realized that yet. They have given the lenders the tools needed to avoid costly appraisal management oversight departments while at the same time giving them the ability to use only those appraisers willing to make the deals work. They mistakenly believe that by delegating to an AMS or AMC they have met their due diligence requirements.Quality control? Sure. Just ignore the FNMA...

Pressure Can Never Be Removed From Appraisers 7

Gaining Perspective On Our Profession

Pressure that used to be overt has now become covert… I hold no particular pedigree or credential to speak for everyone in the real estate appraisal profession. All I can do is draw from nearly 26 years of being a part of it. In that time, I have heard almost every opinion on every issue that promises to be the next big challenge for our industry. It’s true that like everything, change is inevitable. We adapt to new technologies and practices as well as learn new skill sets. From FIRREA to Dodd-Frank, appraisers have continued to evolve when swift moving...

Copyright of Appraisal Reports: Control Over Our Own Intellectual Property 42

Copyright of Appraisal Reports – Again

Why do we need a copyright in the first place? Before deciding whether you need to copyright, or whether it is too complex or not I urge all to read the information found in the following link. When I started searching to see what the specific requirements were, I initially thought I’d have to pay a fee and submit each ‘work’ (appraisal report) to the United States Copyright Office. Clearly not a practical process for most of us, even if the fee weren’t so high (about $114.00). I’m pleased to say if is not that complicated, or costly. In fact,...

FTC Attorney Response & AGA Seeking Appraisers Opinions 9

FTC Attorneys Response to AGA

Is the FTC asserting that FNMA is exempt from antitrust laws? I don’t think of myself as being obtuse, nor do I think those that know me well would consider me to be particularly slow of wit or comprehension. Despite this, I’m truly confused by the Federal Trade Commission (FTC) attorneys response to the American Guild of Appraiser (AGA) email letter we sent them. The first sentence states “The federal antitrust laws prohibit anticompetitive mergers and business practices that seek to prevent hard-driving competition, such as monopolistic conduct, attempts to monopolize, and conspiracies and combinations that harm competition and consumers.”...

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 38

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...

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