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...
Like so many things in life, the NCUA Board decision was predicated primarily on greed… This is a lot like the liar loans that infiltrated residential lending not that long ago. Appraisers, especially Commercial appraisers, I picked this info up from a message sent out by the Appraisal Institute on July 18, 2019: “The NCUA Board of Directors today quadrupled – from $250,000 to $1 million – the appraisal threshold for nonresidential real estate loans. NCUA is the National Credit Union Administration. The appraisal threshold is the loan amount below which appraisals are not required. Increasing the threshold would drastically...
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...
…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...
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...
No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...
