Author: Dave Towne

Hard Fixed Appraisal Fee in TRID - Possible Changes by CFPB 19

TRID – Possible Changes by CFPB

For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser… Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans. Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments....

Inappropriate Use of GSE Forms for Private Appraisals - AppraisersBlogs 5

Inappropriate Form Use

Why oh why do appraisers who should know better do private assignment appraisal reports using the mortgage lending GSE forms? Here’s an “observation” from an actual report I just happened to see: Do the appraisers who do this not read the parameters (Intended Use & User) of the form?? INTENDED USE: The intended use of this appraisal report is for the lender/client to evaluate the property that is the subject of this appraisal for a mortgage finance transaction. INTENDED USER: The intended user of this appraisal report is the lender/client. Note the “Assignment Type” on the first screen shot. “Marital...

Data and Verification Sources Are Critical 11

Data and Verification Sources Are Critical

The genesis for this essay began when I heard from another appraiser that a VA report reviewer rejected the comparables “DOC Number” on the Verification Source(s) line. The reviewer said the “DOC Number” was not acceptable as a Verification Source. In fact, VA has said in a newsletter to appraisers that “… Assessor’s File Number may never be used as a Verification Source.” I disagree with that position, and this essay explains why. It also explains what appraisers should do to provide credible Data and Verification Source(s) in reports. Caveat: I don’t do VA assignments. I decided that a deeper dive...

National Appraisers Forum - Join Highly Qualified Peers - AppraisersBlogs 16

National Appraisers Forum

National Appraisers Forum is one of the best appraiser groups with a wealth of info participants share freely on a wide number of topics… Appraisers, if you would like to learn from highly qualified peers (other than me! :), post questions, or offer your own comments, consider joining the FREE group, National Appraisers Forum (NAF). Use this link. This group used to be one of the Yahoo groups, but Yahoo is shutting down groups, so National Appraisers Forum has moved to ‘groups.io’ as its home base. If you are not already a ‘participant’ of NAF, the sign-up is easy. If...

Loans Affected by the $400,000 Appraisal Threshold Increase 2

Loans Affected by the De Minimus Increase

NCUA is advocating for an increase in the de minimus to $400K for loans provided by Credit Unions… The $400,000 de minimus is now ‘official’ but it doesn’t apply to most appraisals. Here’s an article from HousingWire, published on 10/8/2019, which correctly states when this change took effect, which you should read. From the article: Now, it’s important to note that the new rules do not apply to loans wholly or partially insured or guaranteed by, or eligible for sale to, a government agency or government-sponsored agency. What that means is that loans sold to or guaranteed by the Federal...

Forward and Reverse FHA Condo Mortgages - Zoning and Solar Photovoltaic 2

FHA Forward & Reverse Mortgages

FHA appraisers, you may begin seeing more appraisal assignments for both FHA ‘Forward’ and ‘Reverse’ mortgages on condos, starting in October 2019. “Forward” is the slang term for a standard mortgage with a set term, paid off during that term. HUD/FHA has changed the eligibility requirements for condo properties to allow senior (seasoned) citizens to apply for a reverse mortgage if that is their primary residence. The change takes effect in October. The change also affects standard ‘forward’ mortgages on condos, making it easier for condo projects to quality for FHA guaranteed mortgages. FHA clamped down on these in 2008,...

The Raising of the De Minimus and Its Impact on the Appraisal Industry 11

De Minimus Impact on the Appraisal Industry

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

Major Threat to Real Estate Agents on Horizon - Appraisers Blogs 6

Major Threat to Real Estate Agents

Appraisers, in case you are not aware, NINE law firms have begun the process to sue real estate agents and brokers across the US about how the commission process works to compensate the SELLING broker. It is believed that three of the best known internet based property purchasing and selling web sites are behind this effort. It’s being done so that they can build their own businesses, while jeopardizing the livelihood of real estate agents and brokers. The suits allege that there is collusion and racketeering among the real estate participants to ‘bake in’ a set commission for the selling agent...

NCUA Board Decision Could Potentially Hurt Commercial Appraisers 8

NCUA Quadruples the Appraisal Threshold

Like so many things in life, the NCUA Board decision was predicated primarily on greed… This is a lot like the liar loans that infiltrated residential lending not that long ago. Appraisers, especially Commercial appraisers, I picked this info up from a message sent out by the Appraisal Institute on July 18, 2019: “The NCUA Board of Directors today quadrupled – from $250,000 to $1 million – the appraisal threshold for nonresidential real estate loans. NCUA is the National Credit Union Administration. The appraisal threshold is the loan amount below which appraisals are not required. Increasing the threshold would drastically...

Property Selection for analysis & Statistics in Appraisals - Appraisers Blogs 11

Property Selection for Analysis & Statistics

The importance of proper property selection and ‘statistics’ in appraisals… Appraisers, I would like to direct you to info written by Mr. George Dell in his latest blog post circulated on July 3, 2019. This is one of the best explanations I’ve seen him write on this topic, of how to select and analyze properties when doing appraisals, and why correct ‘statistics’ presented in reports is important. I first became aware of the importance of proper property selection and ‘statistics’ when I attended an appraiser’s training class in 2008 in Las Vegas. The primary speakers were Mr. David Braun and Mr. Patrick...

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