Category: American Society of Farm Managers and Rural Appraisers

Appraiser Complaint Forms 0

AI Advocates for Issue-Specific Appraiser Complaint Forms

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...

ASC letter RE Launch of the 0

Appraisal Hotline Operations Details

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....

Lenders May Still Profit Most from Appraisal Fees 2

To Disclose or Not to Disclose AMC Fees

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...

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AI Asks HUD to Withdraw Section 8 Provision Eliminating Appraisals

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...

Appraisal Institute Continues to Support Separation of Fees 1

AI Continues to Support Separation of Fees

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...

Proposed Amendments to the Sentencing Guidelines in Mortgage Fraud Cases 1

Sentencing Guidelines Proposal

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...

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 2

Appraisal Institute Seeks Separation of Appraisal and AMC Fees

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...

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