Tagged: Wall Street

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...

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...

Road to Perdition, Paved with IVS by The Appraisal Foundation & IVSC 2

Road to Perdition

It looks like USPAP and IVS are finally going to teach the world to sing in perfect harmony. Didn’t Coca Cola already do that? It’s been awhile since I’ve harped about the International Valuation Standards (IVS) and the International Valuation Standards Council, or their inappropriate influence on USPAP. Perdition Road paving compliments of The Appraisal Foundation under sub contract to MISMO. Unnecessary Bridging from USPAP to IVS provided by TAF. For those unfamiliar with what (IVS) or who (IVSC) they are, the following link may help. Scroll down to the corporate sponsors section. THIS is who the ‘international sponsors’ are....

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...

MISMO, Appraisal Data Mining, Hybrids, and Other Fraud Facilitators 16

Who’s to Blame?

Looking at who and what MISMO Directors are, is it a surprise that FNMA included language in basic appraisal forms resulting in appraisers having infinite liability and no ownership over their own work product IF they do work for FNMA?… European Union General Data Privacy Regulations (EU GDPR) may seem like a stretch for an Appraisers Blog topic, but please bear with me. For some time now, The Appraisal Foundation has been focusing on major international valuation issues other than real estate appraisals. IVSC is one of the bigger and most detrimental misdirection’s they’ve taken as far as impact on...

FHFA Working Paper Credibility Questioned by AGA 10

Working Paper Credibility Questioned

NO REAL ESTATE APPRAISER IN THE COUNTRY IS ALLOWED TO MISS THE MARK BY 7.8% WITHOUT RISKING LOSS OF LICENSE! The Working Paper demonstrates more than anything else, that given an 8-hour work day the computer will take 6 full working days (1.2 working weeks) to arrive at a result that is at best 7.8% error prone. Office of the Director, Honorable Melvin Watt Federal Housing Finance Agency… Dear Sir(s) The American Guild of Appraisers is a Guild within the more than 12 1/2 million members, retirees and family members of our parent union OPEIU, AFL/CIO. In addition to representing...

Foremost Authority? The Appraisal Foundation Has Lost its Way - AppraisersBlogs 4

TAF Has Lost Its Way

How can TAF claim to be any kind of authority, let alone "THE foremost authority" for any of the other disciplines? I personally like and respect the individuals I’ve met from TAF. My strenuous disagreement with TAF are the policies and actions. Not the individuals. The opening or introductory remarks on The Appraisal Foundation’s web page state: The Appraisal Foundation (Foundation) is the nation’s foremost authority on the valuation profession [emphasis added]. The organization sets the Congressionally-authorized standards and qualifications for real estate appraisers and provides voluntary guidance on recognized valuation methods and techniques for all valuation professionals. This work advances...

BPO Outsourced to India Replacing Appraisals 27

BPOs ‘Made in India’

$10 a pop ‘Made in India’ BPO… When saying you’re 'sari' just won’t do. The Blackstone Group is nothing short of legendary. To say it is a 'Big Deal' is an understatement squared. A little background from their website. “Who We Are Our investments are designed to preserve and grow our limited partners’ capital, provide financial security for millions of retirees, sovereign wealth funds, and other institutional and individual investors, and contribute to overall economic growth.” An honorable & worthy objective by any measure. Helping retirees on fixed income, little old ladies, grandmothers and mothers, albeit wealthy ones I’d guess. Sovereign...

Markets & Big Data Fool Proved Forecasting 10

I Got It Wrong…

“…after forty years of studying markets, I got it wrong…” As time goes on, the one thing that appears to be both a societal and financial markets constant, is our inability to learn from our past mistakes. Late, a couple of nights ago (10/23/17), while channel surfing, I happened on an economics program intended to explain the financial crisis of 2008. My apologies for referring to a programming without its name or network. Instead, I had to consider the person who was the primary focal point of the program: Hyman Minsky (see link to The Economist here). Before reading the...

Eliminate the Appraisal Subcommittee too! Appraisal Institute Effort to Eliminate the ASC 38

AI’s Effort to Eliminate the ASC!

Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...

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