Tagged: HVCC

Non-USPAP states - appraisers liability limited to appraisal fee 6

Limiting Appraiser Liability to the Cost of the Appraisal?

I recently got an email from an appraiser I have high regards for. He asked me a simple question that got me thinking. It was: “Why don’t a group of appraisers get together and form an AMC?” I found that an interesting concept. It has been done. Coester was an appraiser and now he is just an AMC. Allen Hummel, an Appraisal Institute icon, has an AMC. Why not? We know it better than anyone. But the devil is in the details. Appraiser’s liability for mistakes or omissions in this appraisal report is limited to a refund of the fee...

Serfs Are Starting to Get Upset 10

Serfs Are Starting to Get Upset

The serfs are PISSED! Apologies. America was not founded by people that ‘went along to get along’, or that were willing to accept economic or political serfdom. Though they did so until a critical mass of frustration was reached. It is human nature to seek and then protect the benefits of privilege. To some extent this is a positive attribute. It’s the foundation of Capitalism. It is only when dishonesty and manipulation of laws becomes prevalent that the system is at risk, and not operating properly. We had dueling to keep honorable people honorable two hundred years ago. That was...

Experience, Education Criteria Input Request & AGA Open Letter 18

AGA Open Letter Regarding Changes to the Criteria

Request for Appraiser Input The AGA sent the below letter to the AQB in response to their outreach asking for comments. Please write them and tell them YOUR views. If you agree with what we have said, then just copy it and add your name to it saying “we agree”. Or don’t copy it, and just say “We agree with the AGA letter”. If there are any significant parts you disagree with, then please ‘except’ those. If you have additional thoughts or suggestions for them (civil ones), feel free to add them. I’ve already received an acknowledgement so I KNOW...

The Decline of Appraisers 26

The Decline of Appraisers

The problem is not simply that too many appraisers are retiring. Very few appraisers are entering the profession. In Illinois, the drop in real estate appraiser trainee applications went from 1,231 in 2005 to only 55 in 2015. That’s an over 95 percent decline. This drastic reduction in new entrants is being seen in states across the country. Many appraisers welcome the shortage, which has already driven up fees in many areas. But many believe the celebration is shortsighted. A decline in the number of appraisers threatens the integrity of lending and undermines the stability of the real estate market…

AMCs vs Public Interest - VaCAP Advocacy 29

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...

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