Tagged: TILA

Appraisal Fee Transparency Act of 2019: Pivotal Point for Appraisers 21

Fee Transparency, Pivotal Point for Appraisers

…appraisers may finally have a chance at making the goal of fee transparency a reality… Keep your eyes open, events are happening fast. Ever since the passage of the Home Valuation Code of Conduct (HVCC) in 2010 and the monumental rise of Appraisal Management Companies (AMCs), one of the main issues appraisers have pressed for is transparency for consumers in terms of the fee split between appraisers and AMCs. Specifically, how much of the actual “Appraisal Fee” being paid by the consumer goes to the licensed real estate professional and how much is withheld by the AMC “manager.” Now, over...

Game Over ServiceLink - AMCs Appraisal Schedule Fees Made Public! 38

Game Over ServiceLink

Now that ServiceLink fee schedule, indicating fees paid to appraisers and fees charged to the lenders, has been released to the public, there is absolutely no reason for in camera review… We are sure you have heard the old saying what goes around comes around, right. Well, here we are again; The FTC vs Louisiana Real Estate Appraisal Board case has been brought back into the spot-light. As you may recall, the LREAB filed a civil case against the FTC in attempt to stop the case against them. That case was denied due to lack of jurisdiction. Then the LREAB...

The Appraisal Management Company Business Model, Deceitful Little Lies 28

Deceitful Little Lies

At some point, appraisers need to take a stand against the appraisal management company business model. There are simply no benefits to appraisal management companies and there is no accountability for their actions. Haven’t we all been abused enough? Do the lenders really understand they are responsible for every action of the appraisal management company? Do the lenders really know the questionable ethics of the appraisal management companies? Are the appraisal management companies lying to the lenders? Deceitful, liars, bait and switch, trickery, fee shoppers, bottom feeders, empty promises and illegal activity are some of the nicer terms used to...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

Suppression of Appraisal Service Free Trade & Fair Price Competition 25

Restraint of Trade Investigation

I am heartened that the Federal Trade Commission has recognized the need to assure that appraisal “…consumers deserve to benefit from a free market where those fees are set by competition.” It appears that your complaint may have been instigated by the very special interests that are most responsible for suppression of appraisal service free trade and fair price competition in America today. By that I am referring to the entities broadly described as Appraisal Management Companies (AMCs), and in this specific complaint – the Federal National Mortgage Association, also known as Fannie Mae and/or FNMA .

Delegates & Senators Pass New AMC Law & Clear Capital Possible Violation 14

Details of the New AMC Law

No paid lobbyist, just appraisers talking with the Senators and Delegates about the abuses of some AMCs… Governor McAuliffe signed SB1573 into law requiring appraisal management companies to pay within 30 days of the initial delivery. This becomes law July 1, 2017. Here is how it happened…. Two appraisers, both small business owners, sat down and had a conversation with Senator Frank Wagner about some of the issues appraisers are facing. By the end of the conversation, the three were on the phone with a representative of Legislative Services drafting the verbiage of the bills needed to help protect the...

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 38

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

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Twisted AMC & C&R Fees Gone Wrong!

This AMC is Just Wrong & Confused! An AMC sent an appraiser the following email this morning: “…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“ Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the...

Low AMC Fees? FDIC Wants to Hear from Appraisers 24

Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

AMCs paying low fees, Appraisers and Regulation Z of TILA VaCAP recently learned of some encouraging news. The FDIC wants Regulation Z to be followed and will enforce it for appraisers. Here is what VaCAP received from an appraiser who reached out to the FDIC: I just had a call from an extremely pleasant lady named Susan Welch from the FDIC Consumer Response Center (1-800-378-9581). I had sent a note over regarding an AMC attempting to get me to sign a “Base Fee Letter” agreeing to a drop of my base fee for full appraisals to $325 from $400-500. She...

Truth-in-Lending Act - RESPA Ingetraged Disclosure - TRID Coming Soon Imagecredit Flickr - Dennis Skley 1

TRID Coming Soon Your Way

Appraisers and others, TRID is coming to mortgage lending on Aug. 1, 2015. In case you have not been paying attention to new aspects surrounding your typical measuring buildings and writing reports on a daily basis, TRID is set to become a major change in the mortgage lending process. TRID is the acronym for the ‘Truth-in-Lending Act/RESPA Integrated Disclosure’ process that applies to every mortgage loan as of 8/01/15.  It was part of the Dodd-Frank Law, with power given to the CFPB agency to devise the rules, forms and process. The intent is to consolidate and simplify processes that have...

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