Tagged: NAIFA

A Contrary Response to The Future of Valuation - Imagecredit Flickr - Simon Cunningham 6

A Contrary Response to The Future of Valuation

Recently an article appeared in WorkingRE about the Future of Valuation. The author is the President of a large and highly respected Appraiser  Peer and Educational Organization.  My own contrary response was either too lengthy, or deemed too critical of a big advertiser for publication in WorkingRE. I thank the hosts of this blog for granting the space. My concern with the author’s views starts with the description of our Real Estate Appraisal profession as ‘valuation.’ The concern is more than mere quibbling over semantics. Valuation is the phrase preferred by the Business Valuation community. They have long been dominated...

Another Win for Appraisers - California 6

Another Win for Appraisers – California

Cooperation between appraisers and multiple appraiser organizations wins the day in California! When is the last time you heard of a State bill that was already passed by both State Houses (Assembly & Senate) in any state, being quashed short of a Governor’s veto? Especially a “consent calendar” item that legislators automatically vote to approve for each other as a legislative courtesy. In less than two months? Let me share a quote from Rey Cano’s regular appraiser newsletter (www.Malibuappraisal.com). Rey, along with George St Johns, was an original co-founder of the California Coalition of Appraisal Professionals (CaCAP), where with full...

Unintended Consequences & Regulatory Issues Facing the Real Estate Appraisal Profession 4

Unintended Consequences of the Dodd-Frank Law and Potential Remedies

For well over a year, the Columbia Society of Real Estate Appraisers and five other nonprofit appraiser groups have been working on an industry paper entitled Regulatory Issues Affecting the Real Estate Appraisal Profession (subtitled: Unintended Consequences of the Dodd-Frank Law and Potential Remedies). The paper is aimed at informing lawmakers of some of the unintended consequences of the Dodd-Frank law as it relates to appraisers and consumers.  We hope that lawmakers will address and correct some of the issues brought to light in this paper. The Letter Over the past year, a select group of professional appraisal organizations have...

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

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Appraiser Confidentiality: USPAP Absurdity

Appraiser Confidentiality: Loose Lips, Big Claims, USPAP Absurdity, and Subpoenas Allegedly “Loose Lips” Cause a Big Claim. A recent and relatively big appraiser liability claim involved a commercial appraiser’s alleged breach of confidentiality.  The damages paid to the plaintiff were significant.  According to the plaintiff’s complaint (my recounting of the facts here is simplified), a lender had engaged the appraiser to perform an appraisal for a construction loan to the developer of a shopping center.  Some of the information received by the appraiser included lease commitments from prospective tenants. The anchor tenant was a well-known retailer.  The appraiser completed the assignment, but...

Appraisal Complaint Hotline Usage 0

Appraisal Complaint Hotline Usage

Four Reasons Why ASA & NAIFA Urge Appraisal Subcommittee to Delay Rollout of National Appraisal Complaint Hotline On February 6 ASA, along with the National Association of Independent Fee Appraisers (NAIFA), sent a letter to the Appraisal Subcommittee (ASC) urging them to delay the planned March 29th implementation of the national appraisal complaint hotline, as required by the Dodd-Frank Act. In pushing for the delay, ASA and NAIFA pointed to several issues regarding the hotline’s formation: That the appraisal complaint hotline was created in a closed process, without adequate stakeholder exposure or input; The hotline, as proposed, violates Congress’s intent...

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline 1

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline

The establishment of an appraisal complaint hotline… The American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) appreciate the opportunity to jointly comment on the Paperwork Reduction Act implications of the establishment of the Appraisal Complaint Hotline system mandated by section 1473 of Dodd-Frank. Although we understand that the public will have an opportunity to comment on the appraisal complaint form itself when it is proposed (described as “the Interagency Appraisal Complaint Form”), we believe the agencies’ October 22nd Federal Register request for comment provides our organizations (and other stakeholders) with an important opportunity to...

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Appraisal Practices Board: A Free Resource for Appraisers

The genesis of the Appraisal Practices Board was the collapse of the housing market in 2008… Congressional Hearing Provides Opportunity to Clarify Purpose – FOR IMMEDIATE RELEASE June 29, 2012. Washington, DC – The Appraisal Foundation (TAF), a non-profit education organization dedicated to professional valuation, testified yesterday before the U.S. House of Representatives, Committee on Financial Services, Subcommittee on Insurance, Housing and Community Opportunity. The hearing, entitled Appraisal Oversight: The Regulatory Impact on Consumers and Businesses, focused on the Appraiser Regulatory System in place today and whether there is need for modifications or improvement of this system. One issue discussed...

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TAF Response to Columbia Institute eVIP Appraisal News

April 6, 2012, Mr. George Harrison, The Columbia Institute Dear Mr. Harrison: This is regarding an item that appeared in the “Ask George” column in the April 2 edition of eVIP Appraisal News. The question and answer relates to Appraisal Sponsors of The Appraisal Foundation apparently being under some type of constraint regarding freedom of expression. You have made a similar claim in a previous column and we thought that it was time to correct the record. You state that “The Appraisal Foundation has a restriction clause–gag rule–in its sponsorship/membership agreement that any sponsor may not publicly criticize the Foundation.” This...

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 0

CFPB Appraisal Fees

ASA has repeatedly stated its belief that the Fed’s interpretation and the massive loophole it created ran contrary to the plain language and clear intent of Dodd-Frank. CFPB Reissues Interim Final Rule On Valuation Independence, Eliminates Federal Reserve Commentary Permitting AMCs To Include Their Own Payments To Appraisers To Comply With Dodd-Frank’s Customary and Reasonable Fee Requirement. On December 22, the Consumer Financial Protection Bureau (CFPB) released an Interim Final Rule dealing with the valuation independence requirements imposed by the Dodd-Frank Act, including the law’s “customary and reasonable” fee mandate. The CFPB’s rule was republished to reflect the transfer of...

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