Category: AMC

FHA vs USPAP - FHA vs USPAP - FHA requirements – Appraisers Caught in Catch 22 111

FHA Requirements vs USPAP

FHA Requirements vs USPAP – Appraisers Caught in Catch 22 Excerpt The new FHA Handbook will become effective on September 14, 2015. There has been much discussion of the implications of changing “should” to “must” in thousands of examples in the Handbook. As a Board member of the Arizona Association of Real Estate Appraisers as well as being on the FHA Roster, I have taken a good hard look at these requirements and then, it hit me as I was teaching the Uniform Standards of Professional Appraisal Practice (USPAP) which is the basis of appraisal standards for every appraiser in...

Another Win for Appraisers - House Bill 651 Appraisal Bd. Recordkeeping & Bkgrd. Checks. 2

House Bill 651 Another Win for Appraisers!

House Bill 651: Appraisal Board Recordkeeping and Background Checks Raleigh, NC – Today Rep. Jon Hardister (R-Guilford) passed House Bill HB 651 – Appraisal Board Recordkeeping and Background Checks – which provides regulatory relief for the real estate appraisal industry. House Bill 651 eliminates the discovery rule for civil action related to real estate appraisals and establishes a five year statute of limitations, which puts North Carolina in line with the United States Standards of Professional Appraisal Practice. This will reduce insurance and compliance costs for real estate appraisers, many of which are small businesses and independent contractors. The bill...

AMC Dangers: Appraisal Management Companies (AMC) are changing how our profession works 4

AMC Dangers to the Consumer

Appraisal Management Companies (AMC) are changing how our profession works. It’s important to know exactly how they are affecting the real estate process, especially if you are a home-owner, looking for real estate or are involved in another part of the property. Who does an Appraiser work for? An appraiser works for “The Client” named in the report who ultimately responsible for the appraiser’s compensation. It is important to realize that while a borrower may have paid a lender or third party the cost of the appraisal, “The client” remains the only party authorized to use the report. The appraiser...

Comment Subscriptions 8

Appraisal Fee Disclosure – Call To Action

Important – Call to Action This must be done by Tuesday July 7 The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. We feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee. Recently 23 state appraiser coalitions including the Louisiana Appraisers Coalition worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the...

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 3

Separating Appraisal Fees from AMC Fees

Disclosures regarding payments for appraisal management services versus appraisal fees On July 1, 2015, the Network of State Appraiser Organizations (NSAO) submitted a joint letter in response to the CFPB request for comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. It specifically addresses the lack of requirement to mandate disclosure to the consumer that the fee paid for an “appraisal” be clearly defined and break down what portion is being paid to the lenders’ third party appraisal management company and which portion of the fee is...

Condo Density Primer 3

Condo Density Primer

Many appraisers still seem confused as to what the form means by density. In the project section of Fannie Mae form 1073 the first line addresses topography, size, density and view. Many appraisers still seem confused as to what the form means by density. Appraisers enter and AMCs approve phrases like: average or typical or even a calculation such as 50 units / 12,975 square feet. Appendix D regarding UAD reporting offers no guidance. What are they asking for and what does it mean? Fannie is looking to see if the existing density can be rebuilt following a catastrophic loss....

AMC Regulation Rule Finally Published in the Federal Register - Imagecredit Flickr - Steven Lilley 1

Federal Register: AMC Final Rule

AMC Regulation Rule Finally Published in the Federal Register Appraisers and others, On June 9, 2015, the Federal Register published the new AMC Registration and Regulation Final Rule: The OCC, Board, FDIC, NCUA, Bureau, and FHFA (collectively, the Agencies) are adopting a final rule to implement the minimum requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) to be applied by participating States in the registration and supervision of appraisal management companies (AMCs). Thanks to Bill Garber, Appraisal Institute Director of Governmental Affairs, for sending me this info today. I first wrote & sent info...

1st Enforcement of C&R Fee Provision Louisiana Makes History - Imagecredit Flickr - Roland Tanglao 5

Louisiana Makes History – C&R Fee

First Enforcement of C&R Fee Provision: Louisiana Makes History Nearly five years after Dodd-Frank set forth rules regarding Customary & Reasonable fees (C&R) for appraisers, an agreement last week between a state board and an Appraisal Management Company (AMC) is the first evidence of enforcement. The bottom line for appraisers is that they may be finally on their way back to customary and reasonable fees. On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) issued a Stipulations and Order Memorandum (SOM) wherein Coester Appraisal Management Group, also known as Coester VMS, offers no admission of guilt but agrees...

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint - Revised Press Release - Imagecredit Flickr - Nic McPhee 1

LREAB Resolves AMC Complaint – Revised Press Release

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint Baton Rouge, LA – – On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) approved entering into a “Stipulations and Order” with Coester VMS Appraisal Management Group. The Order will resolve a pending complaint that alleged that Coester violated Louisiana law that requires AMCs operating in the state to “compensate appraisers at a rate that is customary and reasonable for appraisals being performed in the market area of the property being appraised, consistent with the presumptions of compliance under federal law” (La.R.S. § 3415.15, La. Admin Code. tit. 46,...

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 16

AMC Fined for Reasonable & Customary Fees Violation

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees As a result of a thorough investigation conducted by The Louisiana Real Estate Appraisers Board (LREAB), an adjudication hearing for an appraisal management company was held to determine if that firm is following the laws and rules pursuant to minimum reasonable and customary fees, as required by the Dodd/Frank Act and Louisiana laws and Appraisers Board rules. The case alleges the appraisal management company Coester VMS was not compliant with the state’s AMC laws and...

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