Tagged: FNMA

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 6

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

Need for Speed? AMC vs Direct Lender Ordered Appraisals TATs Study 81

Need for Speed? Hybrids are NOT the Answer!

…surveys indicate that appraisals ordered directly by lenders take much less time… Dear Colleagues, There is a current narrative that appraisals take too long and cost the consumer too much! Does this sound accurate? Preliminary coalition surveys indicate that appraisals ordered directly by lenders take much less time than appraisals ordered by AMCs. Additionally, the cost of Hybrid Appraisals has been disclosed in reports as $495 being paid to the AMC. How is this a savings to the consumer? They get an inferior valuation product and pay the same price as a full appraisal. Who is truly benefiting from this scenario? Fannie...

Crystal Balls Don’t Work When Reporting Market Trends! Nor does the MC Form! 8

Crystal Ball & PFA Techniques

PFA figures & opaque crystal balls don’t work when reporting market trends! Nor does the MC Form! Appraisers, by now you’ve heard that FNMA finally has decided that their 1004MC form is basically worthless. That form is no longer required in appraisal reports for properties sold to FNMA, as of August 7, 2018. poorly designed form which never has reported accurate trends…However, sidekicks in mortgage lending have not come to the same conclusion… yet. Hopefully, in short time, they will also remove the MC ‘inclusion’ requirement in reports of this awful, poorly designed form which never has reported accurate trends – despite the...

IRS & USPAP: Substantially in Accordance with USPAP vs Being USPAP Compliant 0

IRS & USPAP

Treasury Department & IRS BOTH officially adopted USPAP back in 2009… except when they don’t want to follow it… The Appraisal Foundation is once again misinterpreting the very regulations they purport to be reporting and telling consumers to be sure to follow. As a matter of fact by substituting their own verbiage for what Treasury Regulations and IRS (Final Rule) policies actually say, they could be causing extreme harm to untold numbers taxpayers. The following article includes a link that MUST be read to understand all the nuances, and which should be used as the final determinant of what is...

States Back LREAB Against FTC - FNMA Ends 1004MC - Stress Test Failed? 4

States Back LREAB Against FTC

States Support Louisiana Real Estate Appraiser Board against the FTC States (and appraisers) are very interested in the outcome of the LREAB vs FTC to protect their own sovereign actions. On July 11, 2018, the states of Mississippi, Idaho, Iowa, Rhode Island, and Utah filed an amicus brief with the United States Court of Appeals for the Fifth Circuit supporting the Louisiana Real Estate Appraiser Board. See the entire brief here or below. The outcome of this will impact each and every one of us. As we reported a few days ago, one lender, BB&T, has opted to step up...

AMROCK Valuations New Service Seems to Seek Circumvention of USPAP! 10

Can you say ‘L-A-W-S-U-I-T’ boys and girls?

Fellow appraisers I strongly discourage anyone from accepting AMROCK Valuations work generally due to their poor track record in dealing with appraisers across the country; and their apparent habit of making up their own appraisal rules as they go along without regard to C&R fees; Dodd Frank and most other common sense sound appraisal practices up to and including USPAP. Y’all remember USPAP don’t you? A series of uniform rules we’d all follow to promote, preserve and protect the American real estate appraisal profession and the American Public. That is until it became an inconvenient impediment to MISMO; FNMA and...

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...

Waiving Appraisals, Lowering Appraisal Standards, & Raising De Minimis... 13

Waiving Appraisals & Lowering Appraisal Standards

Freddie getting aggressive in waiving appraisals & promoting appraisal free mortgages… Appraisers, Yes, I have a ‘dog in the fight’ with this article, as I have been an Appraisal Institute member since 2003 (along with other association memberships since). But this article provides explanations about changes to the appraisal process I have not seen elsewhere. Excerpt from “Dodd-Frank rollback weakens appraisal standards“ They started to evaluate whether they wanted to raise that appraisal threshold level from $250,000 to some figure… They left it untouched at $250,000 for residential, but they have increased the commercial real estate appraisal threshold level just in the...

Mortgage Fraud, Alert - Appraisal Waivers & Hybrids' Liability Discussions 4

Mortgage Fraud on the Rise

Mortgage Fraud is on the rise. Fannie Mae has released a warning for California, but this could be happening anywhere. The National Real Estate Post (Frank Garay and Brian Stevens) have a short 6 minute video titled “Red Flag Fraud Warning from Fannie Mae” about the warning. Also on the video, markets with declining values have been discovered. Here in Virginia, appraisers have also noted some areas have taken a down turn over the past 4-6 months. Our purpose of sharing this with everyone is not to spread doom and gloom, but to remind each of us to really take...

Secret Revealed: UAD & Appraisal Forms Redesign Coming NOT Soon 20

Secret Revealed… Coming NOT Soon

New initiative will focus on modernization of the current UAD dataset and residential appraisal forms… What I originally described as a ‘rumor’ several months ago has finally been fully exposed. FNMA and FrMAC are in the process of examining the current GSE appraisal forms, which encompass UAD and the MC Form, to ‘finally’ get the appraisal forms & functions into the 21st Century! But it won’t happen for at least 3 years (2021)… by then many current appraisers will be enjoying bon-bons and brewskies while on the golf course, or be on their long-planned world cruise, after chucking their clipboard...

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