Tagged: requirements

Comments Needed for Proposed Rule to Amend Appraisal Requirements 5

Comments Needed on Appraisal Requirement

The OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies’ regulations requiring appraisals for certain real estate-related transactions. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices. The proposed rule would make conforming changes to add transactions secured by...

Proposal to End Appraisal Requirement on Home Sales of $400k or Less 47

Proposal to End Appraisal Requirement

Regulators’ Proposal to End Appraisal Requirement on Some Home Sales of $400,000 and Below… The Federal Deposit Insurance Corp., the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve released a proposal that would increase the appraisal requirement from $250,000 to $400,000, meaning that certain home sales of $400,000 and below would no longer require an appraisal. According to data provided by the FDIC, the agencies estimate that increasing the appraisal threshold from $250,000 to $400,000 would have exempted an additional 214,000 residential mortgages at regulated institutions from the agencies’ appraisal requirement in...

When an Appraisal is Not Required - Appraisals & Evaluations Regs 4

Appraisals NOT Required

…is not required to obtain an appraisal under other law… The Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter to US banks on 10/16/18, which incorporates Appraisal and Evaluation regulations and guidelines. This consolidates previously issued regs and guidelines into one document: Letter  FIL-62-2018 Part 323 – Appraisals Appraisal and Evaluation Guidelines 2000 – Rules and Regulations PART 323—APPRAISALS § 323.3 Appraisals required; transactions requiring a state certified or licensed appraiser. (a) Appraisals required. An appraisal performed by a state certified or licensed appraiser is required for all real estate-related financial transactions except those in which: (1) The transaction value is $250,000 or less;...

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 24

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

Prizes Awarded for Correctly Identifying AMC in Appraiser Contest 37

Appraiser Contest

…multiple prizes will be awarded…correctly identify this LandSafe-like wannabe to win ANNOUNCING NEW APPRAISER CONTEST! Look at the following time requirements from one national [anonymous] AMC. These requirements are so outrageous that advance disclosure to their clients should be a requirement that their policies suborn appraisers to ignore USPAP and encourage appraisers to take improper short cuts. Here’s the challenge… I have redacted the name of this unprofessional company that appears to think their drive to offer what their competition cannot, (or more likely won’t) warrants promoting subpar appraisal practices. All you have to do is correctly identify this LandSafe-like...

Experience Requirements Reduced, College Degree Still Required for CG 18

Experience Requirements Reduced

Sometimes the only substitute for experience, …is more experience. Dear Mr. Traynor: The American Guild of Appraisers has long been on record in opposition to the original requirement for a college degree to become any level of real estate appraiser. This was never a requirement of Congress at all, but rather one developed by the AQB over time. While we are pleased AQB has abandoned the college degree at the licensed and residential certification levels, we are disappointed to see it is still being proposed at the general certified level. We repeat for the record; there is nothing involved in...

Alternative Evaluations... Good or Bad 9

Alternative Evaluations… Good or Bad

All of these "alternative evaluations" are an attempt to reduce the fee of the appraiser… All this talk about alternatives to a full appraisal needs some common business sense added to the conversation. At the end of these comments I will include some of my background and you can make your decision if you think I am qualified to put my 2 cents in this discussion. I have said this before and I will say it again, the lenders (AMC included) just want an Appraisers signature and their E&O insurance with a value and they want it as cheap as...

MLS Photographs to Be Used for Comparable Sales Says Freddie Mac 23

MLS Comp Photos

Using MLS photographs for comparable sales… In its September 2017 Bulletin, Freddie Mac updated its appraisal requirements. One change worth noting is the use of MLS photographs for comparable sales. Freddie Mac now allows copies of MLS photographs to be used for comparable sales without an explanation from the appraiser. While most appraisers welcome this change, others believe that this is another step to remove the appraiser from the process. One appraiser commented: “Anyone that thinks this is great should think about the long term. Freddie is now saying you don’t need your own pictures to prove you did an...

rainee Appraisers Unsupervised Inspections Allowed: Death Grip on Trainees Loosening 29

Death Grip on Trainees Loosening

Allowing associated trainee appraisers to complete unsupervised inspections… Appraisers, and others, A ‘significantly large’ nationwide AMC has notified it’s vendor appraisers that certain lenders contracted with this AMC will now accept appraisal reports signed by properly trained (and presumed properly approved by the State) Trainees as the ‘Appraiser.’ This follows the Jan. 31, 2017 FNMA announcement that they will accept reports signed by Trainees. So far, I have not seen any similar announcement from FrMAC, FHA, VA, or USDA, or any other specific lender. The AMC’s message to their appraiser panel is below. NOTE: This memo says the Trainee is...

AMC Non Grata 12

AMC Non Grata

I’m coining the phrase AMC non grata… Appraisers, There’s an old, accepted diplomatic term being used by US government folks these days: “persona non grata‘. It refers to a diplomat or other approved foreign nation person being involuntarily removed from the host country, on very short notice. In the most recent case it applies to Russians being expelled from the US due to the alleged actions of their government in the last election. ‘Persona non grata’ got me to thinking. We have instances in our profession where AMC’s become expelled from our businesses. So I’m coining the phrase AMC non...

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