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...
Applications plummeted another 74% Recently the AQB held a public hearing in Washington DC regarding Alternative Experience Requirements and what to do about the anemic number of appraisers nationwide. I read their concept paper when it came out and I’ve read the testimony of those who submitted ideas. I didn’t attend and I didn’t offer up any written solutions. Back in 2005, I remember when everyone was so fired up about finally raising the bar, insomuch as formal education was concerned. They were going to make appraisers in the image of CPAs and lawyers. Four year degrees would be the...
I am not selling road-apples to my fellow appraisers… Appraisers as a group DO NOT PAY ATTENTION to what is going on within the profession OR seemingly unrelated areas that affect the profession. FNMA & Freddie ALREADY HAVE authority to fund loans without appraisals. This is in anticipation of an appraiser shortage. AI has appointed itself the ‘voice of all appraisers’ in America. They actually made the statement at the California TAF meeting in June that they speak for all appraisers interests AND that they put those interests of the entire profession above their own. (source-live meeting; TAF/ASB Redondo Beach...
Executive Summary Appraisers, I spent two days last week at the Appraisal Summit and Expo in Las Vegas – which was extremely well planned and presented – co-sponsored by the Columbia Institute and the National Association of Appraisers. Over those two days, in just about every topic presentation seminar, we appraisers were cajoled and implored to improve info we provide in reports to back up our stated value. We were told that most reports reviewed by lenders are deficient in this aspect. I admit that my reports need improvement in that kind of presentation – although over the years many...
Help Wanted – Day Laborers Needed …. Inquire at any AMC The Dodd Frank act requires the lender to be responsible for their agents. This means the lender is responsible for the actions of the AMC. Do the lenders know what their AMC’S are doing? Probably not. The Dodd Frank act also requires the most qualified appraiser be selected for each and every assignment. What vetting is done by the AMC’S to ensure the most qualified Appraiser is selected? Many AMC’S have the false mentality every appraiser is qualified and competent to appraise every piece of real estate. This simply...
CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs. AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession. In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement. First, the Feds have made it very clear that lenders...
How many appraisers do you know that are enthusiastic about the future of our profession? How many appraisers believe that they are alone in the fight to save their profession? How many appraisers do you know that feel trapped in a “no win” situation with increasing liability and time commitment without being properly compensated or appreciated? My name is Jan Bellas. I am the National Membership Coordinator for the American Guild of Appraisers (AGA). Please give me a few minutes to tell you how the AGA can help you and other professional real estate appraisers. AGA is a national organization focused...
The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...
Recently an article appeared in WorkingRE about the Future of Valuation. The author is the President of a large and highly respected Appraiser Peer and Educational Organization. My own contrary response was either too lengthy, or deemed too critical of a big advertiser for publication in WorkingRE. I thank the hosts of this blog for granting the space. My concern with the author’s views starts with the description of our Real Estate Appraisal profession as ‘valuation.’ The concern is more than mere quibbling over semantics. Valuation is the phrase preferred by the Business Valuation community. They have long been dominated...
Is THAT free enterprise? I’m surprised anyone in the business today sees any minimum pricing proposal as being anti-free enterprise. Contrary to popular belief we have not had free enterprise in the GSE appraisal process since HVCC first reared its ugly head. AMCs ‘telling’ us to pick a number from $250 to $350, or that ‘THEY pay’ $325 per 1004 is NOT free enterprise. I’m an old timer (1986) that was brought up on what used to be AIREA (now the AI) & SREA (now gone) positions that free enterprise and the Sherman Anti-Trust Act prohibited us from ‘even discussing’...
