Tagged: HVCC

AMCs vs Public Interest - VaCAP Advocacy 21

AMC vs Public Interest – VaCAP Advocacy

Since the beginning, Federal Regulation of the industry was initiated to “protect the public. “ FIRREA, USPAP, HVCC, Dodd Frank and state licensing of appraisers and appraisal management companies were initiated with consumer protection as the goal. Customary and reasonable fees, mandated by Dodd Frank, are also to protect the consumer. The Virginia Coalition of Appraiser Professionals supports customary and reasonable fees and believes in order to determine a customary and reasonable fee all things associated must be considered and incorporated into the determination. The below practices by AMC’s are not in the interest of protecting public trust and go...

Appraisers and Their Lack of Fees - Appraisal Cost 12

Appraisers and Their Lack of Fees

I feel it’s only prudent to put my ten cents, or more, in on the subject of actual cost, versus paid fees for appraisals After an overwhelming outpouring of response from appraisers all over the country, I am compelled to write a follow up article to “Appraisals and The Real Cost of Doing Business.” I must stress that my original intent was to highlight the ever increasing cost in all aspects of our industry, passed on to our clients, due for the most part to increased compliance requirements, additional staffing required to monitor said compliance, Dodd Frank rules, HVCC, TRID...

Free Enterprise an Appraisal Myth 40

Free Enterprise an Appraisal Myth?

Is THAT free enterprise? I’m surprised anyone in the business today sees any minimum pricing proposal as being anti-free enterprise. Contrary to popular belief we have not had free enterprise in the GSE appraisal process since HVCC first reared its ugly head. AMCs ‘telling’ us to pick a number from $250 to $350, or that ‘THEY pay’ $325 per 1004 is NOT free enterprise. I’m an old timer (1986) that was brought up on what used to be AIREA (now the AI) & SREA (now gone) positions that free enterprise and the Sherman Anti-Trust Act prohibited us from ‘even discussing’...

“Customary” & “Reasonable” Fees Exclusive Oxymorons 10

‘Customary’ & ‘Reasonable’ Fees – Oxymorons

If WE don’t set ‘reasonable’ minimums for ourselves, then others will do it for us (or to us). Fellow appraisers, Please read this draft proposal for minimum national appraiser fees. I appreciate those who believe no one other than themselves should set fees, and I concur. Except, in the real world of today someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition. I’m interested in your meaningful, constructive feedback as well as comment & discussion here. For those that insist ONLY regional fees are practical, this same system works...

Skewed Customary Fee Perceptions - Imagecredit Flickr - Quinn Dowbroski 14

Skewed “Customary” Fee Perceptions

I no longer care about “customary”. “Customary” in Dodd-Frank’s customary and reasonable is a negatively biased fee before state studies begin! We all know that the “C” part of C & R is supposed to represent the normal fee charged by most appraisers for similar work and conditions. Some AMC appraisers even know the “R” part is supposed to be an amount that is reasonable based upon ALL factors necessary for completion of the assignment in a USPAP compliant and professional manner. Unfortunately HVCC and the AMC havoc it wreaked has existed far too long for there to be a...

TRID Impact on Appraisal Fees 7

TRID Impact on Appraisal Fees

Appraisers, The Consumer Finance Protection Bureau (CFPB) has mandated new residential mortgage application and disclosure procedures, which take effect Oct. 3, 2015. Here’s a link to a brief article about this. When a consumer applies to a mortgage lender, the lender requests certain information from the consumer before the clock starts ticking in terms of ‘timing requirements’ on the consumer’s application. When the application is considered “complete”, the lender has 3 business days to provide the consumer with the Loan Estimate document. What’s of concern among lenders and appraisers is the speculated inability to change appraisal fees, which is disclosed...

Appraisers - The Reason You Have No Business Functional Obsolescence - Imagecredit Flickr - Howard Lake 16

Appraisers – The Reason You Have No Business: Functional Obsolescence

Functional obsolescence is the reason many appraisers are going out of business. On a daily basis, appraisers moan: “It’s because of the HVCC that my business is down” or “that AMC or X or Y or Z caused my income to decline.” Really? Are you sure? So, why is my company buried in business and you’re not? We’ve all heard about blacksmiths being out of work; Seems the use of horses has declined. And the need for typewriter repairmen, the demand just isn’t what it was 20 years ago. The people in these jobs failed to adapt; Maybe appraiser are having the same problem....

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Evolution of C&R fees – Alter Your Thinking

Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...

I Did Not Quit when HVCC, UAD and CU Came Along. I Do Not Quit, Not Ever - Imagecredit Flickr - Andew Hurley 8

I Do Not Quit, Not Ever!

I Did Not Quit when HVCC, UAD and CU Came Along. I Do Not Quit, Not Ever! I do not quit. Not ever. I have a different perspective based on lifelong lessons from my father. I did not quit when a lost helmet in the last play of the season made it painful to block during high school football. That effort got me my school letter despite being 3 quarters short. It was worth the headache. I did not quit Boot Camp in 1969 when at 129 pounds and six feet, very few thought I’d make it. To this day I...

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Time to Bring Back Common Sense

Appraiser No More, Think I’ll be a Lawyer: it takes less time to get a law degree than to get an appraisal license. I heard from an old friend today that worked as an appraiser in Raleigh, NC for at least a dozen years. Shortly after 2009 and the HVCC, he (like so many others) started looking for career options. After appraisal reports kept requiring more and more pages, had more and more restrictions (far too many that were totally useless and had nothing to do with the home’s value), and his fees kept going down instead of up, he...

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