Some title group pushed a simple premade form letter and there are two or three hundred exact or near exact match letters submitted.

Four days left. Write your letters now if you have not already please.

https://www.regulations.gov/document/CFPB-2024-0021-0001

This one is interesting;
https://downloads.regulations.gov/CFPB-2024-0021-0385/attachment_1.pdf
Suggestions regarding the cost of appraisals:
The New England Associations would also like the Bureau to consider itemizing the cost of an appraisal. The
industry predominately orders appraisals through independent Appraisal Management Companies (AMCs).
There is no required disclosure to separate the fee that is paid to the AMC versus the appraiser. We should
ensure that regulated institutions are fully cognizant of the practices of AMCs they hire. By disclosing the
appraisal fee breakdown on the mortgage disclosures, we believe that it will be easier for an institution to
monitor the practice of appraisal selection and track the amount that the borrower-paid fee goes towards the
appraisal.

Thank you. Estate is always available. If one was also comfortable dealing with lawyers, court rooms, all of that. Although still an appraisal service, that is significantly different then being in the consumer protection realm with origination.

Here are a few of the comments submitted worth reading, which came from groups not just individuals;

https://downloads.regulations.gov/CFPB-2024-0021-0040/attachment_1.pdf

https://downloads.regulations.gov/CFPB-2024-0021-0045/attachment_1.pdf

Last week and only a few days to submit comments. Next week is the last week. Fifty comments. Sad that tens of thousands of appraisers harmed by these amc practices, so very few even bother to keep up with industry news and these events. Most appraisers lost their passion for the industry because of appraisal management companies, they left the spirit of consumer protection and care for Americans needing home loans many years ago and never looked back. Who could blame them? However, the harm imposed on the American populace in general continues unabated. ‘Appraisal modernization!’

Thank you Mr Baggins for these mail contacts.

I for one just renewed my appraiser license last week at 70 years old and as usual I am busy as all get out.

My focus in real estate appraisal has been estate work and legal work with lawyers since 2020 to the present.

The Covid Times were great as all I did was The Rush and turned down 40 calls a day for low priced AMC work.

But it has been described as a water faucet being turned off when appraisal requests dry up. So you have to have a plan B or a back up plan .

99.5 percent of my work is Non Lender Work. There is a lot of work out there but appraisers who sit and wait for the phone to ring without marketing their skills to the public beyond the AMC’s have a terrible business model plan.

Presently I have 8 estate appraisals on my desk this week to complete that are all Non Lender Work reports, so you can see I really don’t care about AMC’s or that type of work because that is not where Money Is.

How much are appraisals fees going to be using the redesigned multiple purpose URAR Form in 2025?

That is yet to be determined, but all I know is that the form is significantly increased in page length and will take more time per report.

Good luck to all of you.

Flash

https://www.regulations.gov/document/CFPB-2024-0021-0001

^^True Dat again Bags !!
I’m from the Gubment and I’m here to help ! NO THANKS !!!!!

The intimidation factor is baked in for everybody. Personally I like the idea of decentralizing DC and the federal government in general. The local boards have never and will never be able to hold centralized power to account. Citizens hold that power. Which is why the citizen must never be honestly informed.

The final line of the article tells the tale; ‘America’s beleaguered homebuyers can no longer afford the high cost of the federal government’s protective services.’ Define; Racketeering. The plunder continues.

True Dat Bags 😉
6 or 7 years ago I proposed to our State Coalition to propose to our State Board that NC mandate that the Appraiser Invoice be page 1 of all AMC reports. They discussed it, tabled it and it disappeared. Are AMC lobbyist controling most State Boards as well as AARO.net ?? It appears so….. But that’s just my opinion, I could be wrong.

Thank you to the CFPB for nullifying the original intent of the Dodd Frank Reg Z rule on C&R billing, which would otherwise have resulted in a $10k/$20k recurring daily fine for any amc and lender violations of the fair and transparent appraisers fee billing rule standards. The underlying motivation is not just raking billions of dollars in junk fees from improperly co mingled appraisal service and amc third party appraisal service handling fees. The junk fee windfalls also allowed the amc and lending industry to monopolize and consolidate, thereby providing many other ancillary services which used to be provided by independent companies, now under the amc umbrella instead. The final goal nearly achieved; Eliminating independent appraisers completely, gaining total control of the valuation checks and balances process. aka; ‘Appraisal modernization’.

Good luck with fair representation on your next mortgage loan. You’re going to need it.

https://appraisersblogs.com/amc-engagement-letter-appraisers-do-not-include-your-invoice/

Interesting headlines coming out of RESPA News ?