Tagged: Veterans Affairs

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? 4

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...

Fee Survey....Survey Says! Appraisal Fee Increases & 2017 Surveys 19

Fee Survey…. Survey Says!

Fee Survey Results & Fee Increase…. Appraisers have certainly been hearing a lot of negativity lately and we finally have some good news to share. The Veterans Administration has completed its fee survey. This is good news as the VA now considers $525 as the normal fee for non-complex properties in Virginia. This equates to a 16.5% increase from the previous fee of $450. To see the new fee schedule for Virginia, District of Columbia, Kentucky, Maryland and West Virginia, please click here or see table below. The fees become effective 09/01/2017. Greetings, The purpose of this communication is to...

Clear Capital Push For Hybrid VA Appraisals 54

Clear Capital’s Push For Hybrid VA Appraisals

Clear Capital suggests that the VA consider the use of a desktop appraisal On April 4, 2017, the House Committee on Veterans Affairs held a hearing on “Assessing VA Approved Appraisers And How To Improve The Program For The 21st Century.” The hearing was designed to “assess VA’s current appraisal process, as well as specific difficulties for timely appraisals in highly rural areas”, as well as to investigate possible technological solutions to mitigate timeliness issues. Much of the hearing focused on two areas: The requirements for becoming a member of the VA appraiser panel, and the baseline requirements for comparable...

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...

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