Tagged: Interim Rule

The Appraisal Profession & Appraiser's Business Decimated by the Increasing Dominance of Appraisal Management Services - AMCs 15

Appraisal Profession Decimated by Appraisal Management Services

The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...

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...

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