https://www.regulations.gov/document?D=OCC_FRDOC_0001-0233

Click open docket folder. Then click view all in comments.

578 total comments recorded.

Great job Jennie! If I can ever be of any assistance to you or your associates down in the metro L.A. area or Long Beach, let me know.

Baggs, great information (PLEASE break posts up with a couple line breaks or paragraphs though…hard to follow for these old eyes).

I never read Garns-St. Germain but now I will in my spare time though. When I worked as an appraiser in IRS/LB&I; my primary function was review of Estate and Gift Tax appraisals. It’s interesting to note that IRS taxes an estate based upon the ownership interest that is passed from the estate; and NOT on the basis of what is received by the heirs. Those interests CAN be different.

Because the ‘transfer’ is an instantaneous event in time, I have to wonder about the federal tax implications IF a lender was able to enforce a due on sale clause against an estate? Even the big boys don’t get to claim rights over those of the U.S. that precede their P-notes!

You can argue that its in the promissory note, but you also have to consider the sovereign powers of the State (as in USA) which supersede everything else. ALL property rights in America derive from one of  the following sources: English Royal Patents & Common Law; Spanish Land Grants and (U.S.) Government patent.

So, the/any ‘rights’ I may have in my property are subject first to the rights reserved by the government via Spanish Land Grant(s) modified by the Treaty of Guadalupe Hidalgo (I think): and made subject to U.S. Governmental Police Powers. Back east you folks were mostly Royal Patent based.

Now please stop leading me astray with such interesting and educational posts! *G*

Outstanding Mr. Thomas! (thanks Bill)

I’d pay $39 a month with no contract before Id pay NDC, CoreLogic, LoopNet and others a dime!

Now the fun part (separate from above)

I urge every reader here to take the 15 day free trial and start running AVMs on your own house, 2-4s in your area, friends houses and even current listings or recent sales in your area and report back with your conclusions. Lets keep notes folks. IF this unassisted service is any good, then lets acknowledge it so that we can go find new careers before all the good shifts at McDonald’s are all taken!

Dear Sir or Madam:

I greatly appreciate the chance to comment on the review of existing regulations regarding “Appraisals.: Standards for Federally Regulated Transactions” under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) (Docket FFIEC-2014-001).

After working as a real estate agent for ten years and then earning an appraiser’s license, I Immediately noticed a difference in the ways agents and appraisers measured and viewed square footage. I started tracking sqft errors in the MLS, public records, and in automated valuation products. After over ten years of research, I have recently had approved two appraisal CE classes. The first titled ANSI, Home Measurement & the Power of Price-Per-Square-Foot; and the second titled Public Records, Square Footage, and the Real Estate Information Crisis. Both classes address the extensive problems with automated valuations.

Most automated valuations are based on the sqft details contained within public records. Those records are inaccurate in the majority of homes, enough so to change home values. In large urban areas they are more accurate than others, but across the country these errors are alarming. Especially in homes with upper or lower levels, these errors are significant. Inaccurate sqft details, when utilized in a price-per-square-foot formula, create over and under home valuations. The public records system was never designed or intended to provide precise sqft data, and the automated valuation industry relies on this highly inaccurate data. AVMs are hurting the real estate industry. Unsuspecting homeowners (and real estate agents) often based home prices on the totals listed by an AVM, which can be above or below true market value.

To extend the appraisal limit from $250,000 to $500,00, based on these highly inaccurate programs, would hurt consumers. It’s a system whose basic premise is flawed and in our current price-per-square-foot world, these numbers change home values and do harm to consumers. The appraisal industry is the best chance to protect consumers and no computerized system can ever replace the skill, experience, and local knowledge of a professional appraiser.

I strongly encourage you NOT to adopt any action that would increase the current appraisal threshold levels of $250,000. Based on my research, raising appraisal thresholds would decrease the safety and soundness of real estate lending practices.

I would be happy to elaborate about the problems with public records and square footage, and how that data impacts automated valuation services, and/or answer any questions. Thank you for your time and consideration.

Respectfully Submitted,
D Hamp ThomasInstitute of Housing Technologies
Carolina Appraisers
26 Pinecrest Plaza #165
Southern Pines, NC 28327

Mike click here. 259 comments now with yours/AGA’s at the very top.

Baggs,

I sent a cover letter for 13 million AGA/OPEIU/AFL-CIO TAXPAYING CONSUMERS opposing:

1. Deminimus increase-I actually made an argument as to why it should be LOWERED to $100,000.

2. PACE PRO from First American; owner of ACI. Worst “product” ever and BY ITSELF among the best arguments for reducing the deminimus.

Go ahead and sue me First American! You ought to be banned from originating ANY loans though your mortgage arm. If PACE Pro is a typical example of your professionalism, your clients are being HOSED! By the way appraisers, BOYCOTT the software company they own. You may have heard of it. It’s called ACI! Why should we support those trying to drive us out of business? You advertise far more than is delivered via that format. You will be lucky if state attorney generals and local jurisdictions ONLY talk to you about advertising far more than can be delivered in the vehicle you brag so much about online.

3. Example of Big Data inaccuracy. $3.4 million property in Los Angeles reported as $17+ million dollar sale IN ERROR! COMMON error in data accumulators. Affected the average and median by DOUBLE what it should be. Suggested regulators ban ALL AVMs except those actually designed or operated by appraisers on a case by case basis…such as a comp check based value estimate, and even then only with full disclosures.  don’t expect this one to fly but at least they know the “Big data” in to lenders and AVM operators is GARBAGE!

4. Requested that FNMA CU be banned and explained how flawed it is (article previously printed in here)

5. As long as I was writing anyway; suggested C&R should be as per website http://www.appraisersguild.org May not have made that point as strong as Id have liked, but frankly I couldn’t read the computer screen anymore by that time.

HOW TO count the comments, and read them:

Click the egrpra link provided in the lead article. Click the submit a comment link on top, then click it again in center. New window loads as regulation dot gov. Click the title link like you would to read the main article, directly above the noted ID: FFIEC-2014-0001-0126 identification number. On the right it states current comment counts. Right now it is at 141. Then scroll down on the right bar to the docket information section on right hand column, and under related comments, click the view all link. That leads to a counter which states 259 related comments. I suspect that may be the count difference between attachments and not, or officially identified businesses vs not, I’m not sure. In the 259 comments section, click the sort by posted newer-older. And that’s it. Click and read, etc, etc. It’s obvious whom the appraiser commenters are, because we’re the only ones with personal names in the lead for comment post identification.

How could you tell? Counter was at 207 when I first looked, but could not see actual comments. Could you? IF we get 100 appraiser comments, even with 200 industry comments we have a GREAT chance this wont go through! Usually they get almost MO comments from us so this would be a big deal to them.

Works for me! Oddly enough if it was their own investors money at risk and not insured money, there’d be a LOT more demand for GOOD appraisers, even a the top of the fee ranges.

Wow, so how many foreclosures run through monthly, that otherwise could have gone to the family.  Who said diversify away from mortgage lending work?  Why?  Apparently land is the next big appraisal rush, and reo continues on despite any market climate, due to aggressive servicers.  Wait, how do deminimums apply to land? Raise deminimums and minimum land ltv investment points at the same time.  You’ll see the carpetbaggers rushing blm lands for miles and miles.  It’s not there to be sold, but I can see so many of these complex intricate ploys coming to fruition in many diverse locations.  There should be a specific exemption that blm lands cannot be sold or considered to fall under this regulatory framework.  The implications of these changes when considered with the big picture of today are remarkable to say the least.

Thank you Mike for being on top of this.  Unbelievable.  Someone please start a thread on the AF, to boost the comments quantity.  I did not see any of the names of the appraisers forum regulars in those letter sets.  I cannot post there anymore, because I refuse to turn adblock off.  Someone should though, that group should be good for at least 50 more comments in a single day just today.  Post a thread with; “Rush, need letters today”, and link them over here for the rest.  Remarkable.

I posted my comment to the link yesterday. 🙂

Reply to JS. Great letter.  Good, compelling read.  Hope you sent that in to the official location.  Thanks.

Good man! Thank you!..Likewise Bill, above

Agree with 99.9% of what you said! Usually the deminimus is employed where HELOCs are involved, though it could be used for first mortgages too. Whether anyone is listening or not depends on whether you sent this to the link provided in the article at top of page. TOMORROW is the DEADLINE

I spent eight hours today and several hours last week drafting letters and back up documents to upload on behalf of 13,000,000 taxpayers and consumer members of AGA, OPEIU & AFL/CIO.

I KNOW the cover letters will be read. It is possible the back up data will be as well.

We (AGA, OPEIU/AFL-CIO) specifically asked that deminimus not be raised, but further that it be LOWERED to not more than $100,000. We also addressed C&R fees, Collateral Underwriter and the lack of credibility of almost ALL AVMs and AVM based products where no appraiser developed and applied the AVM search & screening criteria; and specifically how bad a product the First American PACE Pro is.

Presumptive minimum fee in Virginia is now $450. IF appraisers WANT that, then they need to ALL update their profiles. In a week or two Coester will either be paying it, or you will know there are others in Virginia that do not believe THEY are worth more than peanuts.

Lic. Res. Appraiser, I ASSUME this was before Virginia passed the $450 presumptive minimum C&R fee.

I appreciate there are two issues here. One of which is being worked on by national ‘appraisal factories’ that hope to capitalize on the plight of licensed appraisers and trainees (not to infer the former is similar to the latter) by getting AMCs and lenders that use them to accept trainees (presumably at MUCH lower than C&R rates).

The other issue which is more hopeful is the possibility that AQB MAY provide an opportunity for experienced non certified appraisers like yourself, to upgrade your license WITHOUT the four year degree currently required. It is NOT a lowering of entry standards, but rather recognition of the value of your experience. Those of us at the American Guild of Appraisers, OPEIU/AFL-CIO have worked on this with many other individuals, and organizations and have presented testimony to TAF and it’s Boards concerning how this one fact alone is driving many appraisers away.

An appraisal license IS something to be proud of; or at least it used to be. Those of us that like you, have been around awhile know they weren’t handing those out for the asking. One of the BEST residential appraisers I know is licensed rather than certified. Its the result of skill, knowledge, integrity and a great work ethic.

IF it is any consolation, your post will be read by numerous Virginia Coalition of Appraisal Professionals; and possibly by state regulators, that are already aware how COESTER pays LESS than C&R fees, and then tries to rationalize that. You’ve just shown how it is done. Thank you.

Also the turn time! Not overlooked is that they didn’t bother to check your qualifications to see if you were qualified for the assignment they gave to you BEFORE they gave it to you. Reasonable folks would conclude then that the assignment was based on the LOW FEE rather than specific qualifications and property complexity.

Hopefully the folks at VREAB will read this, but there is not much they can do since you provided no order number or other identifiers that they cold track.

If you still have the specific records on this one and are a member of VaCap contact Pat Turner; or if a member (or want to be a member) of AGA then contact me. (714) 366 9404, Mike Ford or mike@mfford.com; or janbellas@appraisersguild.org (301) 220-4100. This IS the kind of thing we’d love to investigate further if you are so inclined.

Wow! Ofelia you just gave me a Homer Simpson moment with the beauty and simplicity of your suggestion! I just spent eight hours compiling documents to send to the folks over at: OCC; Board of Federal Reserve and FFIEC. I WISH I had included YOUR comment.

Absolutely BRILLIANT! I bow humbly in your direction Ma’am IF you sent this to the comment links previously link provided.

If it helps I asked for a REDUCTION in the deminimus to $100,000 along with support; opposition to PACE Pro; support for C&R at government Civil Service rates as opposition to ALL AVMs, BPOs and alternative products.