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...
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...
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...
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...
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...
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,...
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...
VaCAP has learned that another AMC might be having financial difficulties. There are conversations currently taking place in two appraiser groups on Facebook. The discussions revolve around bounced checks from an appraisal management company. The comments are varied and some are stating they are having no issues with this particular appraisal management company when it comes to payment. Others are stating invoices are past due from April and late payments have been the norm with this amc recently. One commenter stated their bank has issued a hold on checks from this amc. Then there is the original post from an...
Has Coester risen from the ashes? Apparently, per a message on Twitter on July 9, 2019, Mr. Brian Coester is now in the real estate sales biz. The photo image used on the big T is the same one he used to use on his defunct AMC website. More information here for re-posts of articles not written by him. Meanwhile, there appears to be a new twist in Evaluation appraisals. This is the first I’ve seen about an AMC or any other company using ‘the homeowner’ to supply interior photos which will be used in a bank evaluation. See this...
Appraisal management companies do not understand the nuances of the appraisal profession, nor do they understand the challenges many rural properties bring. The Virginia Coalition of Appraiser Professionals has submitted an official comment to the ASC opposing the State wide appraisal waiver request in North Dakota. VaCAP has submitted a public comment expressing concerns over the much larger consequences in allowing such a request. A blanket waiver of appraisals up to $500,000 for a 5 year period will have a devastating impact on housing, not only in North Dakota, but across the country. We envision a snowball effect with other...
