Category: Illinois Department of Financial & Professional Regulation

Appraisal news for real estate appraisers and real estate professionals regarding Illinois Department of Financial & Professional Regulation (IDFPR). News relating to the Appraisal Industry.

Third Party Inspectors, Hybrids... Spelling Out the Consequences 10

Hybrid Assignments, the Consequences

The concept of a third party providing one or more functions in an appraisal assignment is nothing new. Back in the 1970s and 1980s there were plenty of appraisers who used somebody else to do the sketch or to take the pictures or to pull comps. The “appraiser” put all of the pieces together and signed the report. Then came USPAP in 1989. Licensing followed shortly thereafter. Today, there are a number of lenders and AMCs who believe that they’ve invented something no one else has ever considered. The bifurcated or hybrid appraisal process. To be clear, we’re not talking...

Community Bankers Voice Their Concern About Real Estate Appraisal 19

Bankers Concerned About Appraisals

Community bankers said appraisals are becoming a concern… A survey was distributed by state banking regulatory agencies in April and remained open through July. More than 600 community bankers from across the U.S. lent their voices to this year’s survey, and those views are captured in this volume. Responses are summarized and presented in following five major areas: Local market conditions; regulation and supervision; small business lending; management structure and succession planning; and technology. The responses provide context for the data gathered through the survey and highlight some of the dierent challenges faced by community banks in different states. The...

Significant Appraisal Assistance, Outsourcing & Third-Party Blues 25

Third Party Blues

What is the significant part of significant contribution? Most lenders would rather not do the work of cultivating and curating a panel of appraisers. This is largely why AMCs exist. AMCs, in turn, quietly off-load some of their activities to other subcontracted entities. Some AMCs contract out state licensing and registration compliance responsibilities to outside concerns. A few use portals to send out engagements to their panel of appraisers. Others farm out payroll and invoicing. Still others outsource their QC work. This begs the question: What exactly do some AMC’s provide…directly? Some appraisers, too, don’t seem to be interested in...

Amendments To Sales Contract - Contract Amendments - When? 5

Contract Amendments… When?

Amendments to Sales Contract & Updates to the Appraisal… Fannie Mae recently issued the following: Currently, we require the lender to provide the appraiser with all amendments made to a sales contract, including amendments that are made after completion of the appraisal. With this update, we have clarified when the appraiser must be provided with updates to the sales contract and circumstances that warrant updates to the appraisal. For example, if the contract is amended in a way that affects the description of the real property used by the appraiser, then the lender must provide the updated contract to the...

Appraisal Regulations - Life After Dodd-Frank ~ copyright AppraisersBlogs 5

Life After Dodd-Frank

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

Residential Appraisers Being Phased Out 20

Appraisal Alternatives

Computers eliminating “boots on the ground” residential appraisers. An historian once quipped, “I cannot predict the future, but give me six months and I’ll tell you why it was inevitable.” Residential appraisers who work in the mortgage arena began to experience the sea change when UAD arrived amongst much fanfare in September of 2011. Years of portals, hard-stops, and overrides have settled into an uneasy routine. We’ve already seen changes to closing docs as a result of TRID (TILA RESPA Integrated Disclosures). That adventure began in November 2013. Washington DC, never content to maintain any level of consistency has already...

AMC Indemnification & Catchall Certification 7

AMC Indemnification

Appraisers signing off catch-all certification… When we crafted the language in the AMC Act back in 2011-2012, we followed what most every other state included insofar as indemnification was concerned. (225 ILCS 459/165) Sec. 165. Prohibited activities. (8) Requiring an appraiser to sign any sort of indemnification agreement that would require the appraiser to defend and hold harmless the appraisal management company or any of its agents, employees, or independent contractors for any liability, damage, losses, or claims arising out of the services performed by the appraisal management company or its agents, employees, or independent contractors and not the services performed...

Digital Masking of People a Fair Housing Requirement of Mythodology 27

AMC Fair Housing Mythodology

AMCs are on notice to cease demanding and insisting that appraisers do digital staging. You’ve seen the AMC’s orders. “Appraiser is to obscure, blur or remove individuals from photos.” Why? Fair housing laws say so, that’s why. Do they? I had my first settlement conference with an AMC recently. Appraisers have been participating in settlement conferences with Appraisal Board members and Department attorneys for years. Because there is no Board for AMCs, the opportunity falls to me. At issue was the ubiquitous “client requirement” involving digital masking of people from images. While lenders and AMCs wave the Fair Housing penalty...

Evaluation vs appraisal - a lesser product for even lesser money? 7

To Eval or Not to Eval

An evaluation, when performed by an individual acting as an appraiser, is an appraisal… Recently, a document entitled, The Interagency Advisory on Use of Evaluations in Real Estate-Related Financial Transactions was released. Many in the lending and appraisal professions see this as a federal permission slip for evaluations to be completed by Illinois Certified Appraisers. The document reiterates what we already know about evaluations: Under the appraisal regulations, the following transaction types do not require an appraisal, but do require an evaluation: Transactions in which the “transaction value” (generally the loan amount) is $250,000 or less; Certain renewals, refinances, or other transactions involving...

When Residential Appraisers Fail to Bracket 5

There Go My Brackets

When appraisers fail to bracket… Forget college hoops and all of the upsets. This is about the upsets that occur when residential appraisers fail to bracket. Say that your subject property has a contract for $102,900. Ideally your three sales should surround the contract price like a cozy, warm blanket. Comp #1 might end up, after adjustments, at $100,000. Comp #2 might reach $102,500 and Comp #3 might conclude at $104,000. Yay! All you need is a pretty bow and you can deliver a lovely report to your client. But…it really doesn’t work that way on most days. Does it?...

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