Tagged: Veterans Affairs

Loans Affected by the $400,000 Appraisal Threshold Increase 2

Loans Affected by the De Minimus Increase

NCUA is advocating for an increase in the de minimus to $400K for loans provided by Credit Unions… The $400,000 de minimus is now ‘official’ but it doesn’t apply to most appraisals. Here’s an article from HousingWire, published on 10/8/2019, which correctly states when this change took effect, which you should read. From the article: Now, it’s important to note that the new rules do not apply to loans wholly or partially insured or guaranteed by, or eligible for sale to, a government agency or government-sponsored agency. What that means is that loans sold to or guaranteed by the Federal...

The Raising of the De Minimus and Its Impact on the Appraisal Industry 11

De Minimus Impact on the Appraisal Industry

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

Landmark Acquired by Class Valuation - VA Drops 1004MC...Done Deal! 13

Done Deal

AMC Consolidaton – Class Valuation (formerly Class Appraisal) of Troy, MI is acquiring Landmark Network, of Van Nuys, CA. This document does not say ‘when’ it will occur, or if the transaction has concluded, but the way it is written, the implication is that it’s a “dun deel.” Anybody have any scuttlebutt on which of the hundreds of the remaining AMC’s might be next to be consolidated with another one? Landmark Network’s email: Hello! Eleven years ago, I set out to create a different kind of appraisal management company. One that truly valued our appraiser partners while embracing the efforts...

Comments Needed for Proposed Rule to Amend Appraisal Requirements 8

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...

The Public Trust - A Failed Goal? - Rearranging the Deckchairs on the Titanic 8

The Public Trust – A Failed Goal?

Presumably, "public trust" is the foundational test. Have our institutions, rules, regulations, standards, and social expectations failed us? The purpose of the Uniform Standards of Professional Appraisal Practice (USPAP) is to promote and maintain a high level of public trust in appraisal practice by establishing requirements for appraisers. Preamble 2018-2019 Our mission is to foster the public trust of our members and the appraisal profession through compliance with the highest levels of ethical and professional standards. The American Society of Appraisers Its mission is to advance professionalism and ethics, global standards, methodologies, and practices through the professional development of property economics worldwide. The Appraisal Institute Some ten years ago, financial...

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...

States Back LREAB Against FTC - FNMA Ends 1004MC - Stress Test Failed? 5

States Back LREAB Against FTC

States Support Louisiana Real Estate Appraiser Board against the FTC States (and appraisers) are very interested in the outcome of the LREAB vs FTC to protect their own sovereign actions. On July 11, 2018, the states of Mississippi, Idaho, Iowa, Rhode Island, and Utah filed an amicus brief with the United States Court of Appeals for the Fifth Circuit supporting the Louisiana Real Estate Appraiser Board. See the entire brief here or below. The outcome of this will impact each and every one of us. As we reported a few days ago, one lender, BB&T, has opted to step up...

BB&T Adopts VA Appraisal Fee Schedule & Will Refund Appraisers Upload Fees 10

Appraisal Fee Increase & Upload Fees

VaCAP has learned from one of our members, BB&T will be following the Veterans Administration Fee Schedule moving forward. They will also being reimbursing appraisers for all upload fees. This is exciting news. Please share with your contacts and clients. See the announcement below. To: BB&T Approved Mortgage Appraiser Continuing our commitment to compensate appraisers with fees which are customary and reasonable, BB&T utilizes the Veterans Administration’s published fee schedule as a foundation. We wish to inform you that we are adjusting our mortgage fee schedule to remain consistent with recent fee increases announced by the Veterans Administration to certain states in...

Improper Direction to Appraisers as a New Special Lender Condition 21

Improper Direction to Appraisers

…specific prohibited direction to appraisers involved in federally regulated transactions… Improper direction to appraisers as a new special lender condition Honorable Ladies and Gentlemen: The following article appeared in a recent online post at http://appraisersblogs.com/appraisers-asked-2-overlook-weed-cultivation (also copied to this letter following our inquiry). We consider the original author to be a credible source. Due to the serious implications of any appraisal management service giving such specific prohibited direction to appraisers involved in federally regulated transactions we believe it to be our duty to bring this to your collective attention. We respectfully request that each Federal Regulatory Agency review this issue...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

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