The establishment of an appraisal complaint hotline… The American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) appreciate the opportunity to jointly comment on the Paperwork Reduction Act implications of the establishment of the Appraisal Complaint Hotline system mandated by section 1473 of Dodd-Frank. Although we understand that the public will have an opportunity to comment on the appraisal complaint form itself when it is proposed (described as “the Interagency Appraisal Complaint Form”), we believe the agencies’ October 22nd Federal Register request for comment provides our organizations (and other stakeholders) with an important opportunity to...
Appraisal Complaint Hotline The Appraisal Subcommittee, a federal monitor of state bodies responsible for governing valuations, will open an appraisal complaint hotline by the end of the year, HousingWire reported July 2. The appraisal complaint hotline, required by the Dodd-Frank Act, will allow homebuyers, real estate agents, lenders and others in the industry to file complaints about appraisers and appraisal management companies. “ASC member agencies are currently working to finalize the details for how they will handle the referral of a complaint from the hotline,” ASC Executive Director James Park noted in House testimony, HousingWire reported. Park reported that a...
Fed Report Scrutinizes Appraisal Processes The Government Accountability Office released a report June 28 that scrutinized real estate valuations in the wake of the recent mortgage crisis. The report, Residential Appraisals — Regulators Should Take Actions to Strengthen Appraisal Oversight, was produced using data from Fannie Mae, Freddie Mac and five of the biggest mortgage lenders. The report revealed that valuations received through broker price opinions and automated valuation models take less time and are less costly than traditional appraisal reports, but traditional appraisal reports are still mandated for almost all first-lien residential loan originations due to their greater reliability....
NAR believes that lenders should be prohibited from retaining the services of an AMC where the lender maintains any level of ownership. Frank Gregoire‘s written testimony to the United States House of Representatives Committee on Financial Services Subcommittee on Insurance, Housing and Community Opportunity before the Appraisal Oversight Hearing … APPRAISAL ISSUES AND CHALLENGES There are a myriad of circumstances and issues working to hinder the recovery of the nation’s housing market. Among them, and often overlooked, are those related to the credible valuation of real property. A credible valuation provided by a licensed or certified professional 1) ensures the...
My testimony today will focus on issues that are particularly relevant to state regulatory officials. Challenges Facing State Appraisal Boards Enforcement States established appraiser licensing and certification programs as a result of the Financial Institution Reform, Recovery and Enforcement Act (FIRREA) of 1989. These agencies issue appraiser licenses and certifications to those individuals who possess the education and experience requirements promulgated by the Appraiser Qualifications Board of The Appraisal Foundation. The agencies also oversee compliance by appraisers with the Uniform Standards of Professional Appraisal Practice (USPAP), state law and agency rules. These programs have been set up in a variety...
“Appraisal Oversight: The Regulatory Impact on Consumers and Businesses” Hearing Frank Gregoire, a a state-certified residential appraiser in Florida, will testify on behalf of the National Association of REALTORS® (NAR) before the House Financial Services Committee’s Insurance, Housing and Community Opportunity Subcommittee on Thursday, June 28th. The hearing will focus on the appraisal industry and regulations impacting consumers and businesses. Mr. Gregoire holds the RAA Designation, is a two-time Chair of NAR’s Appraisal Committee, and has been active in NAR’s public policy committees since the early 1990s. Mr. Gregoire is on Panel II of the hearing. WITNESS LIST Panel I...
TAF Response to Columbia Institute eVIP Appraisal News April 6, 2012, Mr. George Harrison, The Columbia Institute Dear Mr. Harrison: This is regarding an item that appeared in the “Ask George” column in the April 2 edition of eVIP Appraisal News. The question and answer relates to Appraisal Sponsors of The Appraisal Foundation apparently being under some type of constraint regarding freedom of expression. You have made a similar claim in a previous column and we thought that it was time to correct the record. You state that “The Appraisal Foundation has a restriction clause – gag rule – in its...
Where To Direct Questions and Comments Regarding Customary and Reasonable Fees The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB...
FOR IMMEDIATE RELEASE – February 2, 2012 Contact: Paula Douglas Seidel, Executive Administrator, The Appraisal Foundation Washington, DC — A recent survey conducted by the Government Accountability Office (GAO) of state appraiser regulatory programs has produced high marks for The Appraisal Foundation regarding its effectiveness in issuing appraisal standards and appraiser qualifications. The survey, which was performed in conjunction with the GAO study issued last month entitled “Real Estate Appraisals: Appraisal Subcommittee Needs to Improve Monitoring Procedures,” contained 65 questions relating to the effectiveness of the current real property appraiser regulatory system. In addition to the effectiveness of the Foundation,...
On January 18, 2012, the US Government Accountability Office (GAO) released their report on real estate appraisals “Appraisal Subcommittee Needs to Improve Monitoring Procedures” as required per Dodd-Frank. GAO was tasked with 1) determining how the Appraisal Subcommittee (ASC) is carrying out its Title XI responsibilities, 2) ASC’s plans to implement Dodd-Frank provisions, and 3) regulatory dollar thresholds for determining when an appraisal is required. GAO reports that one of the challenges faced by ASC is in the area of resources and planning. GAO cites the creation of a national hotline as one example of a Dodd-Frank requirement that could...
