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...
Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...
VA Announces Electronic Appraisal Requirements: Appraisals must be in MISMO XML Effective June 1, 2014, all Department of Veterans Affairs (VA) appraisals will be processed in WebLGY under the VA Appraisal Management System (AMS). Therefore, beginning June 1, 2014, all VA appraisals must be uploaded in WebLGY in Mortgage Industry Standards Maintenance Organization (MISMO) compliant XML 2.6 GSE file format as VA will no longer accept appraisals uploaded in WebLGY in PDF format. Prior to June 1, 2014, VA appraisals must continue to be uploaded in WebLGY in PDF file format. Historically, VA appraisal form/formats conformed to appraisal industry form/format...
Appraisers to be paid within… It is all-too-rare that we hear positive news regarding the appraisal profession. There is an awful lot of complaining that goes on, most of it justifiable, but little good news that gets shared. Part of the problem is that there is no central source for information regarding our profession which appraisers might utilize in order to find out what is going on across the country and affecting our profession, and could be used to enhance our industry and our citizens in our own state. From what I have seen, most of any good news is being...
…“preaching” about the basics of this industry… The more I read residential mortgage related appraisals, underwriter comments and comments from the quality assurance departments from major lenders, the more I have come to realize that it is far beyond time to get back to “preaching” about the basics of this industry. For those of you who have been in the business back when you would take the photos, pull it out of the camera, wait a few moments before you pulled the front off the photo before coating it with the “magic wand” to keep it from fading (thank you...
Is Sharing a Report with a Fellow Appraiser a Violation of USPAP Confidentiality?…Appraisers routinely share confidential information & communicate assignment results with other appraisers… Appraisers frequently are faced with chances to make mistakes related to confidentiality. The Confidentiality Section of the ETHICS RULE of Uniform Standards of Professional Appraisal Practice (USPAP), as published by the Appraisal Standards Board (ASB) of the Appraisal Foundation and enforced by the North Carolina Appraisal Board, provides the rules for appraisers in North Carolina. Appraisers often are reminded about and advised how to avoid the pitfalls of communicating with property owners, real estate brokers, lenders...
In 2012, AI requested the removal of the references to the AOs and FAQs from the Commission’s regulations…. On April 8, the Maryland Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors completed action on rulemaking that removed the Advisory Opinions and Frequently Asked Questions of the Uniform Standards of Professional Appraisal Practice from being incorporated by reference into the state’s appraiser licensing and certification laws. The move addresses the Appraisal Institute’s long-standing concerns about increased regulatory burdens placed on professional appraisers. Prior to this rule change, the AOs and FAQs were considered by the Commission to be...
Fannie Mae’s new “Appraiser Quality Monitoring” initiative that creates an appraiser “do not use list” or “blacklist” has alarmed many working appraisers, especially since at least a portion of the process is automated. Placing an appraiser on a Fannie Mae exclusionary list would effectively end a career, therefore, it is critical that appraisers…
Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...
The most critical failure found in appraisal reports that come before the Board, whether residential, commercial, or agricultural, is a lack of analysis. Appraisers seem to think that citing or reporting is synonymous with analysis. Analysis – to study (something) closely and carefully: to learn the nature and relationship of the parts of (something) by a close and careful examination. The URAR asks: I did or did not analyze the contract for sale for the subject purchase transaction. Explain the results of the analysis of the contract for sale or why the analysis was not performed. Yet many will write:...
