Tagged: HVCC

AGA Statement to House Financial Services Committee Hearing 3

AGA Statement to House Financial Services Committee Hearing

The American Guild of Appraisers Statement to House Financial Services Committee Hearing Madam Chairman and Members of the Committee, on behalf of the American Guild of Appraisers/OPEIU Guild 44 (AGA) thank you for the opportunity to submit this statement in connection with today’s hearing on the real estate appraisal profession and the regulation of appraisers and appraisal practice. The AGA is a membership organization that seeks to represent the interests of appraisers related to federal and state regulation of appraisal practice and to industry practices that impact on appraisers and appraisals. In addition, working closely with other like-minded organizations including...

Statement of Frank Gregoire (NAR) Before Appraisal Oversight Hearing 3

Statement of Frank Gregoire (NAR) Before Appraisal Oversight Hearing

NAR believes that lenders should be prohibited from retaining the services of an AMC where the lender maintains any level of ownership. Frank Gregoire‘s written testimony to the United States House of Representatives Committee on Financial Services Subcommittee on Insurance, Housing and Community Opportunity before the Appraisal Oversight Hearing … APPRAISAL ISSUES AND CHALLENGES There are a myriad of circumstances and issues working to hinder the recovery of the nation’s housing market. Among them, and often overlooked, are those related to the credible valuation of real property. A credible valuation provided by a licensed or certified professional 1) ensures the...

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Challenges Facing State Appraisal Boards

My testimony today will focus on issues that are particularly relevant to state regulatory officials. Challenges Facing State Appraisal Boards Enforcement States established appraiser licensing and certification programs as a result of the Financial Institution Reform, Recovery and Enforcement Act (FIRREA) of 1989. These agencies issue appraiser licenses and certifications to those individuals who possess the education and experience requirements promulgated by the Appraiser Qualifications Board of The Appraisal Foundation. The agencies also oversee compliance by appraisers with the Uniform Standards of Professional Appraisal Practice (USPAP), state law and agency rules. These programs have been set up in a variety...

NAIHP call to action 1

NAIHP Urgent Call to Action

NAIHP: “Congressional Subcommittee REFUSES Small Business Brokers and Appraisers a Seat at the Table” For the second time in a week, the Subcommittee on Insurance, Housing and Community Opportunity, Chaired by Rep. Judy Biggert (R-Illinois), refused small business housing professionals the right to be represented during Congressional testimony. On June 20th, the Subcommittee held a hearing entitled: “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses?” Although, Banks were represented three times on the panel, Brokers were intentionally excluded. NAIHP argued to represent the industry, but was refused because the panel was full. On June 28th,...

HVCC & Interim Rules Unintended Consequences 7

NAIHP Letter Regarding Appraiser Independence Regulations

An outline exposing the unintended consequences created by HVCC and the Interim Rule February 23, 2012, Hon. Richard Cordray, Director, Consumer Financial Protection Bureau Re: Appraiser Independence Regulations Dear Director Cordray: Thank you for taking the time to meet with NAIHP on January 26, 2012. We always appreciate the opportunity to meet with the CFPB and discuss issues of concern that affect consumers and small business housing professionals. Although, our meeting covered a broad range of issues, my comments today are limited to the ongoing problems associated with “Appraiser Independence.” Today’s interim Rule on Appraiser Independence, was built on the...

NAIHP Exposes AMC Tax Evasion / RESPA Violations 1

NAIHP Exposes AMC Tax Evasion / RESPA Violations

AMCs violating RESPA NAIHP recently discovered many Appraisal Management Companies (AMC’s), are operating without authority in most states and have failed to pay state income tax. When businesses are formed, they are required to register with their Secretary of State, for authority to conduct business. That registration alerts the State Tax Department you exist and may be responsible for certain taxes. The same holds true if you operate outside your home state, according to Marc Savitt, NAIHP President. “Most AMC’s are only registered in a handful of states, but operate nationwide. If you’re not registered, you’re not paying taxes,” said...

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“Public Trust Betrayed”

Congresswoman Jackie Speier letter to author of “Public Trust Betrayed” James E. Manning, author of “Public Trust Betrayed”, an appraiser in California who began his career in 1973, received a letter from Congresswoman Jackie Speier in response to his book and the state of the appraisal industry: December 30, 2011 – Mr. James Manning Dear Mr. Manning: Earlier this year you offered me a copy of your book, Public Trust Betrayed.  After some delay, I have finally had an opportunity to briefly review it. I agree with many of your conclusions. For example, you indicate that existing laws created after...

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‘Middleman’ Appraisers Spur Concerns

If you’ve paid for a home appraisal within the last five years, a chunk of that charge likely went to a middleman you never knew existed. And because a third party was used, it might have driven up your closing costs and affected the quality of the valuation. Lenders often use appraisal management companies to block collusion between mortgage brokers and appraisers — and to comply with anti-fraud rules the industry adopted in May 2009. The hotly debated reforms have boded well for the appraisal managers, whose presence in the U.S. has jumped from a handful in the 1990s to...

Wanted: Angry Appraisers 12

Wanted: Angry Appraisers – BankRape

Wanted: Angry Appraisers Experienced residential appraisers have spent the past 30 months wishing for change and wondering if it would ever come.  Most were fooled into believing that justice could be found by writing to politicians, signing petitions, and waiting for their state agencies and appraisal organizations to fix the problem. Nearly two years passed and the remaining appraisers continue to tread water while scanning the horizon for signs of a rescue.  Appraisers awakened on April 1, 2011 (Appraiser Fool’s Day) with renewed hope, only to find that the tiny clause within Dodd Frank, “customary AND reasonable fees” had been altered...

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Appraisal Management Companies Create More Problems Than They Solve

When the final chapter on this housing crisis is written, I hope that I am still around to see those who were responsible for its cause and the feeble attempts to fix it held responsible. One of the worst fixes is the Home Valuation Code of Conduct. Enacted in 2009, HVCC was spearheaded by then New York Attorney General Andrew Cuomo. His objective was to rein in appraisal abuses by the lenders sending loans to Fannie Mae or Freddie Mac. A noble goal, but by the time this so-called fix went into action many of the worst offenders were either...

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