Category: AMC

Appraisers Should Never Do Evaluations - Appraisers Blogs 15

Appraisers Should Never Do Evaluations

…users of evaluations knew & accepted that if they obtained evaluations in lieu of real appraisals that they were getting meaningless value opinions by unqualified personnel… TALCB will be considering the Board’s position regarding appraisers performing evaluations in compliance with USPAP at the next Board meeting on August 23, 2019 Dear Texas Appraisers Licensing & Certification Board Members: The short and sweet version is that appraisers should never, repeat never do ‘evaluations’. The term itself should never be uttered as if it refers to any legitimate appraisal product that meets the USPAP requirements of a real estate appraisal. When FIRREA...

Bifurcated Appraisal Fans Can Claim SOW Till They're Blue in the Face 50

Hybrids vs USPAP Scope of Work Rule

Supporters of the bifurcated appraisal can claim scope of work till they are blue in the face… Appraisal Buzz published an article written by Joshua Walit on July 31, 2019 titled Nothing New Under the Sun: The Varied Face of Appraisal. The article brings up some good points, however; it does not take into account the reality of the market and the control of the lenders and appraisal management companies in the process. The mere fact that the appraiser does not have control over the person completing the inspection and in most cases, no way to even know who is providing the...

Holding AMCs Responsible for Hybrid Inspections - AppraisersBlogs 11

AMCs Responsible for the Hybrid Inspection

It seems holding the appraisal management companies responsible for the hybrid inspection is the best option. The thinking was they choose, engage and pay the inspector. The Virginia Real Estate Appraiser Board met for its quarterly meeting on July 30, 2019. We are happy to report CoesterVMS no longer has a license to operate in Virginia. The Board voted to accept the consent order accepting the voluntary surrender of his license. The Board also passed a motion to draft legislation to be introduced into the General Assembly giving the Board regulatory control over the hybrid inspection and those individuals that...

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...

Existing Regulatory Burden on Appraisal, a Proven Failure- System Reform 6

Appraisal Reform or System Reform

It is my hope that the Subcommittee on Housing, Community Development and Insurance consider long-term impact. The existing regulatory burden, a proven failure, may insure a repeat of the past. The body of a letter to the U.S. House Committee on Financial Services about systems reform. Appraisal reform or Appraisal industry reform? It is critical to understand that ‘appraisal’ does not equal ‘valuation’, or risk analysis, or anything else.  It is a precise definition of a nebulous product. The current U.S. House Committee on Financial Services is asking the question: “What’s Your Home Worth? A Review of the Appraisal Industry.” I believe it is...

DOJ Investigates Big Tech - Atlantic1 AMC Not Paying Appraisers 8

DOJ Investigates Big Tech

The Department of Justice announced last week they have initiated a review of anti-trust concerns with Big Tech Companies. From the Wall Street Journal article, the Federal Trade Commission and the Department of Justice collaborated on who would take the lead on this investigation. Also pointed out in the article, both the FTC and DOJ are pursuing separate investigations of Big Tech Companies. Although CoreLogic was not named as an initial target, we suspect it is just a matter of time before they are included. Frank Garay and Brian Stevens did a short 6 minute video on the subject which...

Proposed Hybrid Meeeting - Overwhelming Majority Were Against Hybrids 5

Overwhelming Majority Are Against Hybrids

The next Virginia Real Estate Appraisal Board Meeting will be held on July 30th, 2019 @ 10:00 AM. This meeting will be a historic meeting as the board will be discussing the proposed hybrid appraisal guidance document and the corresponding 153 public comments. Also on the agenda, CoesterVMS is listed under the disciplinary cases! Why is this meeting so important? First, the 153 comments is the second highest amount of comments that have been made on any guidance document in the past year. The highest amount of comments on any proposed guidance document was by the Board of Health Professions in which 727...

Where is the Invoice? AMCs Hiding Fees from Consumers & Appraisers 30

Where Is the Invoice?

Typically when you sell a service, you include an invoice to the buyer or consumer for the services you provided. This invoice lays out the products sold, the quantities, and services provided as well as the price or fee charged. The invoice is a vital part of any business. It is an official document that businesses use to show the terms of the agreement, it specifies the buyer of the product or services, and it documents the terms of payment. An invoice allows businesses to keep track of payments made or outstanding payments due. Some business will even tack on...

Bill Requires AMC to Disclose their Fee and Fee Paid to the Appraiser 12

Full Transparency in Fee Disclosure

Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the appraiser by the AMC… HB 3619 has been referred to the House Financial Services Committee. VaCAP has learned over the weekend that HB 3619 has been introduced in the US House of Representatives. HB 3619, short titled “Appraisal Reform Act of 2019” amends the Financial Institutions Reform, Recovery and Enforcement Act. The main change to  FIRREA deals with appraisal management company and appraiser trainee registries and the addition of a member of the Veterans Affairs on the Appraisal Subcommittee. The bill also modifies Section 2603,...

North Dakota Appraisal Waiver Granted 8

North Dakota Appraisal Waiver Granted

News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...

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