Tagged: waiver

Appraisal Waivers and Hybrid Appraisals False Narrative - Quality Matters 23

Appraisal Waivers and Hybrid Appraisals

The fallacy of those who endorse Hybrid appraisals is their assumption that the appraiser’s field work is less valuable, less important, than their analytical work behind a computer. They feel the task of inspecting the property and driving comps is best farmed out to someone else with less training. The real truth is that the field work is critical! There is no way an appraiser can credibly analyze a property through the eyes of another… The Need for Speed: In a previous post entitled The Need for Speed, I explained that lenders and Appraisal Management Companies are on a mission to shorten the...

Appraisal Waiver Questioned by Legislators- Asking ASC for Justification 8

Appraisal Waiver Questioned by Legislators

Late Friday afternoon, VaCAP learned the Financial Services Committee Chairwomen. Maxine Waters and Senator Sherrod Brown, Ranking Member of the Senate Committee on Banking Housing and Urban Affairs, sent a letter to the Appraisal Subcommittee Chairman Arthur Lindo inquiring around the circumstances of the North Dakota Appraisal Waiver that was granted a few months back. The exact verbiage used in the letter to describe the waiver was “unprecedented with minimal justification.” This speaks volumes as to their concern. Congress has repeatedly recognized the essential role that appraisals play in both safety and soundness and consumer protection. That is why it is...

War on the Appraisal Industry. Another Great Real Estate Depression 11

The Collective Rot

Over 11,000 appraisers signed that petition… The US Congress completely ignored it and, as a result, The Great Real Estate Depression followed. Déjà vu: Or is it Déjà Poo (I’ve heard this crap before)? The Collective Rot Growing Within the Shadows of the Great Real Estate Depression We are just 11 years past the beginning of the Great Recession. Some estimate the US suffered a $14 trillion loss in wealth. Others estimated the loss as high as $21 trillion. This event is more commonly referred to as The Great Real Estate Depression by those of us who are or were in the real estate industry...

Lenders Want to Eliminate DTI Cap! What Could Go Wrong? 20

Lenders Want to Eliminate DTI Cap!

No DTI CAPS – What could go wrong? Well, the insanity continues. HousingWire is reporting that a coalition of lenders and trade groups are calling on the CFPB to eliminate the debt to income cap on all qualified mortgages. Yes, you read that right. Lenders want to eliminate the debt to income cap to allow more loans to be originated. They claim by using alternative factors to determine risks, more low income borrowers can obtain a mortgage. Mortgage Bankers Association President and CEO Robert Broeksmit stated: With respect to the 43% DTI threshold, it makes little sense to commit to a rigid requirement...

We Became Complacent... Appraisers Are to Blame - Appraisers Blogs 33

We Became Complacent

We raised a fuss when it first came out, but we became complacent and accepted what was being dictated to us. Appraisers are supposed to be messengers of the market, right? If that statement is accurate, the question everyone needs to be asking is why appraisers are not allowed to do their jobs? Without getting into a lot a finger pointing and blame, I am just going to come right out and say it. Appraisers are to blame. Not because appraisers wanted to influence the market, but we allowed others to take control and we sat by and did nothing....

Price Fixing & Discrimination - FNMA & FHLMC Bond Price Fixing Claims 7

FNMA & FHLMC Bond Price Fixing Claims

Are the profits being reported by Fannie and Freddie being skewed because of price fixing? In an article released on CNBC by Reuters, US District Judge Jed Rakoff ruled investors can pursue antitrust claims against banks for conspiring to fix prices of bonds from Fannie Mae and Freddie Mac. According to the article, there are transcripts of chat room discussions that prove a conspiracy to price fix mortgage backed bonds from Fannie and Freddie between January 2009 and January 2016. Rakoff wrote. The chats unmistakably show traders, acting on behalf of those defendants, agreeing to fix prices at a specific level before...

The Appraisal Management Company Business Model, Deceitful Little Lies 29

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...

Sunshine Act - Federal Agencies Changing FIRREA & Raising De Minimis 5

Federal Agencies Changing FIRREA

VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraisal waivers in North Dakota. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies...

White Swan Predicts that the Next Recession Is Inevitable 10

The Black Swan – Another Meltdown

Another Meltdown – The Inevitable Outcome of a White Swan: Why would we allow another Financial Meltdown to occur? …When revenues and profits decline, lenders and financial institutions throw caution to the wind and relax their once prudent lending policies in favor of more aggressive, inclusive policies… Hindsight has taught us that there is no serious consequence to imprudent lending policies. Perhaps a multi million dollar fine is assessed but that is just the small cost of doing business for some violators… Though more common now, especially in Australia, Europe, and  Asia, black swans (Cygnus atratus) were once thought to...

Committee Passes H.R. 3619 - Requires AMCs to Disclose their Fees 4

Committee Passes H.R. 3619

H.R. 3619 has passed out of committee and is now sitting in the US House for consideration. H.R.3619 would amend the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to provide the Appraisal Subcommittee with the authority to modify annual registry fees for appraisal management companies, to maintain a registry of trainees and charge a lower trainee registry fee, and to allow grants to States to assist appraiser and potential appraiser compliance with the Real Property Appraiser Qualification Criteria and would require AMCs to disclose their fees. The NCUA Quadrupled The Appraisal Threshold For Nonresidential Real Estate Loans By a 2-1...

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