Tagged: TRID

Hard Fixed Appraisal Fee in TRID - Possible Changes by CFPB 13

TRID – Possible Changes by CFPB

For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser… Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans. Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments....

Do We Really Need Rocket Closing? Home Buying Process is Not a Race 22

Do We Really Need a Rocket Mortgage?

Do we really need a “Rocket Mortgage“? “Rocket Approvals” are nice but certainly not “Rocket Closings”. The home buying process is not a race. It’s not Road Runner and Wile E Coyote racing to the closing table. It takes time! The Need for Speed How quickly do your buyers and sellers want to close on the home they just bought? Two weeks? Four, six, eight weeks? When you wrote the contract, and filled in the “drop dead dates” how much time did you allow for the Title deadlines, the Owners’ Association deadlines, the Seller’s Property Disclosure deadlines, the Loan and Credit deadlines,...

Appraisal Fee Transparency Falls Short - Appraisal Complexity Ignored 9

Appraisal Fee Transparency Bill Falls Short

No system that continues to allow (or limit) defining appraisal complexity to the lender or AMC will ever achieve reasonable, or fair compensation for the appraiser…. We need to do much better than “half a loaf” in our appraisal legislative efforts. Especially when that half loaf does no more than enshrine continued price-fixing by lenders; with the support & blessing of REVAA… WorkingRE published news of recent House of Representatives action. The Bill addresses consumer disclosure of AMC fees among other issues. While the American Guild of Appraisers applauds the efforts of those that worked in good faith on this,...

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...

No Shortage Exists - Bankers Data Proves No Appraisal Shortage Exists 9

No Shortage Exists

No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...

Protecting Appraisers Against Frivolous & Retaliatory 3rd Party Lawsuits 6

Frivolous & Retaliatory 3rd Party Lawsuits

Appraisers are routinely coerced & intimidated by third parties to violate their independence and integrity… Honorable Committee Members: We are writing to add our voice to that of the Massachusetts Board of Real Estate Appraisers (MBREA is a State Coalition of professional real estate appraisers) in support of each of the above bills. The American Guild of Appraisers is a Guild within the Office Professional Employees International Union (OPEIU) of the AFL-CIO, representing the appraisal and real estate related financial consumer / taxpayer interests of over twelve and a half million AFL-CIO Family Union & Guild Members; their families, retirees...

Another Huckster Enters the Appraisal Arena 20

Another Huckster Enters the Appraisal Arena

Yet another third party huckster has entered into the real estate appraiser and appraisal arena. It’s that time again! Yet another third party huckster has entered into the real estate appraiser and appraisal arena. Apparently motivated by pure altruism. We identified a need in the marketplace to address a common problem that lenders are regularly challenged with in providing accurate appraisal quotes and then ensuring pricing on the Loan Estimate is consistent and compliant,” stated Vladimir Bien-Aime, president and CEO at Global DMS. (I LOVE this guy, he writes like me!) Global DMS Launches SnapVal to Provide Instant, Accurate, Guaranteed...

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...

Open Letter to Taxpayers... Afterall, Taxpayers Aren’t Stupid 32

Open Letter to Taxpayers

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

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 .

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