American Society of Farm Managers and Rural Appraisers - Appraisers Blogs

Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
The Illogical Reality of Mortgage Appraisal Reviews Reforming the appraisal review process is essential to maintaining the integrity of the real estate market and protecting consumers and…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

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COVID-19 Temporary Appraisal Guidelines

VaCAP Board — Sun, 29 Mar 2020 12:30:03 +0000

Fannie and Freddie are giving preference to desktop appraisals over exterior appraisals, which quite frankly, is completely backwards from what most appraisers believe to be a more reliable appraisal. HUD and the Veterans Administration, on the other hand prefer exterior appraisals…

Desktop Appraisals Soon to Be the New Purchase Wrinkle The desktop appraisals are not necessarily more reliable, which could become an adverse issue for appraisers in the future... Appraisers,…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
Fannie Mae Fraud and Abuse Exposed History of waste, fraud & abuse at this rogue organization... Fannie Mae reported this week it had fired more than…

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Feds Deny Public Hearing

VaCAP Board — Mon, 25 Feb 2019 13:30:13 +0000

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...

Let's Get Rid of Appraisers. What Could Go Wrong? Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened.…
AGA Objects De Minimis Increase Proposal We object to the proposal to increase the de minimis threshold at which no appraisal is required... Sirs: The American…
Standing With Us Protecting Consumers! ...average costs and appraisal turnaround times are minimal... VaCAP joins 29 State Appraisal Organizations in opposing an increase in the…

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Standing With Us Protecting Consumers!

VaCAP Board — Fri, 15 Feb 2019 13:30:57 +0000

…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...

AGA Objects De Minimis Increase Proposal We object to the proposal to increase the de minimis threshold at which no appraisal is required... Sirs: The American…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Road to Perdition

Michael Ford — Thu, 30 Aug 2018 12:30:01 +0000

It looks like USPAP and IVS are finally going to teach the world to sing in perfect harmony. Didn’t Coca Cola already do that? It’s been awhile since I’ve harped about the International Valuation Standards (IVS) and the International Valuation Standards Council, or their inappropriate influence on USPAP. Perdition Road paving compliments of The Appraisal Foundation under sub contract to MISMO. Unnecessary Bridging from USPAP to IVS provided by TAF. For those unfamiliar with what (IVS) or who (IVSC) they are, the following link may help. Scroll down to the corporate sponsors section. THIS is who the ‘international sponsors’ are....

The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

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Virginia is NOT Playing Around!

VaCAP Board — Wed, 17 May 2017 12:30:53 +0000

Two AMCs Disciplined by VREAB… At the May 16, 2017, Virginia Real Estate Appraisers Board Meeting two AMC’s were disciplined by the Board. SettlementOne Valuation Corporation was disciplined in Mississippi, Illinois and Pennsylvania, all for unlicensed activity within those states. SettlementOne was required to report the disciplinary action to Virginia within 30 days, which they did not. The Virginia Real Estate Appraisers Board imposed a $2,500 monetary penalty for these violations of the Boards Regulations. Dart Appraisal was disciplined in Minnesota for providing an estimate of value on the engagement letter to the appraiser. Dart Appraisal was required to report...

The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…

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Appraisers’ Voice Just Got Louder

VaCAP Board — Fri, 21 Apr 2017 12:30:47 +0000

ASA and NAIFA Agree to Move Forward with Merger Consideration The American Society of Appraisers (ASA), the original multidisciplinary valuation society, and the National Association of Independent Fee Appraisers (NAIFA), the leading voice for independent professional real estate appraisers, announced on April 18, 2017, they have reached an agreement to move forward with a Memorandum of Understanding leading to the merger of NAIFA with ASA. Boards for both organizations will provide details to their memberships in upcoming weeks for final consideration and approval. The merger will add to ASA’s nearly 5,000 multidiscipline credentialed valuation professionals in over 75 countries and...

Appraisal Alternatives Computers eliminating “boots on the ground” residential appraisers. An historian once quipped, “I cannot predict the future, but give me…
Details of the New AMC Law No paid lobbyist, just appraisers talking with the Senators and Delegates about the abuses of some AMCs... Governor McAuliffe signed…
You Are Not Alone - AGA How many appraisers do you know that are enthusiastic about the future of our profession? How many appraisers believe that…

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Serfs Are Starting to Get Upset

Michael Ford — Thu, 24 Mar 2016 12:30:00 +0000

The serfs are PISSED! Apologies. America was not founded by people that ‘went along to get along’, or that were willing to accept economic or political serfdom. Though they did so until a critical mass of frustration was reached. It is human nature to seek and then protect the benefits of privilege. To some extent this is a positive attribute. It’s the foundation of Capitalism. It is only when dishonesty and manipulation of laws becomes prevalent that the system is at risk, and not operating properly. We had dueling to keep honorable people honorable two hundred years ago. That was...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
From Data to Value: How Mass Appraisal Delivers Fair… Behind every annual notice of assessments is a complex valuation system most property owners never realize exists. The Appraisal Foundation…
Top DEI Bosses Have a Problem - Diversity The ranks of the new DEI bosses at the financial institutions are no more diverse than the appraisers their institutions…

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Raising Appraisal Threshold Levels

AppraisersBlogs — Thu, 17 Dec 2015 13:30:45 +0000

Adjusting appraisal threshold levels On December 2, 2015, Dave Towne called attention to an article on a potential increase in appraisal threshold levels, which appeared in the ABA Banking Journal. Excerpt: The banking agencies are revisiting the dollar thresholds for their appraisal requirements, FDIC Chairman Martin Gruenberg said in Arlington, Va., today at the final outreach meeting for the decennial Economic Growth and Regulatory Paperwork Reduction Act review. “Based largely on comments we have received during these outreach sessions, we have formed an define working group to review the appropriateness of dollar thresholds for transactions requiring appraisals and other requirements...

Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…
The Real Cause of the Home Value Gap Is the Income Gap Blaming appraisers for the income gap will never solve the real underlying problem... Blaming appraisers for the income gap is…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…

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Response to "A Wakeup Call for the Valuation Industry: Is anybody listening?"

AppraisersBlogs — Fri, 10 May 2013 12:30:32 +0000

RE: Richard Gilmore, ARA article – "A Wakeup Call for the Valuation Industry: Is Anybody Listening?" I would like to offer some comments regarding Mr. Gilmore’s article in the April 9, 2013 issue of Ag News. I also read most of the NAHB report – "A Comprehensive Blueprint For Residential Appraisal Reform" dated February 2013. I disagree with most of Mr. Gilmore’s comments regarding the NAHB report. The NAHB report lacks a realistic understanding of what is taking place in the real estate appraisal profession today. Most of what is commented on in the NAHB report has been required and/or in place for more...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…

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A Wakeup Call for the Valuation Industry: Is Anybody Listening?

AppraisersBlogs — Tue, 16 Apr 2013 12:30:45 +0000

On February 13, 2013 the National Association of Home Builders (NAHB) published a fascinating critique on the world of valuation. The document: “A Comprehensive Blueprint for Residential Appraisal Reform” should be read by every appraiser, every user and every client. NAHB is telling us our core systems are not working and to take another look at our process and procedures. Our systems are too inconsistent, too cumbersome, and NAHB is asking us to improve our efficiency which impacts their and our profitability. NAHB is asking the industry to provide them a uniform, consistent, quality product utilizing well trained staff. These exact...

Is the GSE's "Appraisal Modernization" Really Just… Mass Appraisal tend to exhibit a regressive nature... In the intricate landscape of real estate mortgage financing, the notion of…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
First the Borrower Fee. Now the Appraiser… Two lawsuits place Class Valuation’s fee transparency and staff-appraiser compensation practices under federal scrutiny. Most appraisal disputes examine only one…

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AI Advocates for Issue-Specific Appraiser Complaint Forms

AppraisersBlogs — Tue, 19 Mar 2013 12:30:36 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 28 to the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Comptroller of the Currency expressing concern about the broad reach of a proposed Interagency Appraisal Complaint form. The agencies intend to provide a copy of the form to individual complainants, who, in turn, will return to the agency for information gathering and potential referral. In its letter, AI and ASFMRA expressed concern that the proposed form may not be the most effective approach and instead recommended complaint forms...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…
Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…

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Appraisal Hotline Operations Details

AppraisersBlogs — Thu, 21 Feb 2013 13:30:15 +0000

Appraisal Institute Wants Details on Appraisal Hotline Operations The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 12 to the Appraisal Subcommittee asking that it make its proposed protocol for operating the “appraisal hotline” available for public comment prior to its March 29 implementation. In the letter, AI and ASFMRA said that while the concept of a hotline is sound, there exists almost no understanding among state appraiser regulatory officials, practicing appraisers and real estate and mortgage professionals as to how the hotline would function or even of its intended purpose....

Is the GSE's "Appraisal Modernization" Really Just… Mass Appraisal tend to exhibit a regressive nature... In the intricate landscape of real estate mortgage financing, the notion of…
Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…

The post Appraisal Hotline Operations Details appeared on Appraisers Blogs.

To Disclose or Not to Disclose AMC Fees

AppraisersBlogs — Thu, 25 Oct 2012 12:30:03 +0000

To Disclose or not to Disclose AMC Fees… With the Consumer Financial Protection Bureau (“CFPB”) up and running, there are numerous regulatory issues still pending relating to the Dodd-Frank Act. The regulatory issues include appraisal independence rules, AMC fee disclosure, AMC registration, required physical property visit by appraisers in “higher risk” mortgages, HUD-1/RESPA Consumer Disclosure, and asset backed securities. Of particular note, the CFPB has proposed a new Consumer Disclosure form that is intended to replace the HUD-1 settlement statement. The proposed rule which was release for public until November, allows disclosure of appraisal management company fees, but does not...

The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
CFPB Crackdown: Unfair Practices Hurting Consumers Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

The post To Disclose or Not to Disclose AMC Fees appeared on Appraisers Blogs.

AI Asks HUD to Withdraw Section 8 Provision Eliminating Appraisals

AppraisersBlogs — Fri, 03 Aug 2012 13:48:51 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers issued a comment letter July 16 in response to the U.S. Department of Housing and Urban Development’s proposed rule on regulatory changes to their Section 8 Voucher Program. The rule proposes to eliminate an existing requirement that an appraisal be used to determine initial rent contracts to a Section 8 building owner. HUD cited a “lack of availability of state-certified appraisers” and “increased expenses in order to acquire state-certified appraisers” as the reasons for eliminating the appraisal requirement. In their joint letter, AI and ASFMRA asked HUD...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…
Is the GSE's "Appraisal Modernization" Really Just… Mass Appraisal tend to exhibit a regressive nature... In the intricate landscape of real estate mortgage financing, the notion of…

The post AI Asks HUD to Withdraw Section 8 Provision Eliminating Appraisals appeared on Appraisers Blogs.

AI Continues to Support Separation of Fees

AppraisersBlogs — Fri, 29 Jun 2012 12:00:10 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers reiterated their support of separating appraisal and appraisal management company fees on mortgage disclosure forms June 20 in Congressional testimony. The organizations originally voiced support when drafts of the Consumer Financial Protection Bureau’s proposed Consumer Disclosure Form were released in February. AI and ASFMRA again expressed their support in written testimony on “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses” before the House Committee on Financial Services’ Subcommittee on Insurance, Housing and Community Opportunity. The organizations expressed support of clear disclosure of...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

The post AI Continues to Support Separation of Fees appeared on Appraisers Blogs.

Sentencing Guidelines Proposal

AppraisersBlogs — Thu, 15 Mar 2012 12:00:00 +0000

Proposed Amendments to the Sentencing Guidelines Speaking at a March 14 hearing in Washington, D.C., the Appraisal Institute urged a federal judicial agency to require the use of real estate appraisals when calculating loss in mortgage fraud cases. In prepared written testimony, Appraisal Institute President Sara W. Stephens, MAI, told the U.S. Sentencing Commission, “We believe the Commission should adopt a special rule for determining the fair market value of real property if the mortgaged property has not been disposed of by the time of the sentencing. However, this rule should require use of real estate appraisals prepared by qualified...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Tapping States for Backchannel Budget Scofflaw U.S. Agency Taps States For Its Backchannel Budget VENTURA, Calif. (February 4, 2022) – History is replete with cautionary…
Dear Representative, FNMA Has Gone Rogue! Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending…

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Appraisal Institute Seeks Separation of Appraisal and AMC Fees

AppraisersBlogs — Tue, 24 Jan 2012 12:00:01 +0000

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Insights from CFPB's Public Comment Period The comment period on the Consumer Financial Protection Bureau's (CFPB) "Request for Information Regarding Fees Imposed in Residential Mortgage Transactions"…
Top DEI Bosses Have a Problem - Diversity The ranks of the new DEI bosses at the financial institutions are no more diverse than the appraisers their institutions…

The post Appraisal Institute Seeks Separation of Appraisal and AMC Fees appeared on Appraisers Blogs.

American Society of Farm Managers and Rural Appraisers - Appraisers Blogs

Insights from CFPB’s Public Comment Period

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Standing With Us Protecting Consumers!

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Road to Perdition

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Virginia is NOT Playing Around!

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Appraisers’ Voice Just Got Louder

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A Wakeup Call for the Valuation Industry: Is Anybody Listening?

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