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’...
If WE don’t set ‘reasonable’ minimums for ourselves, then others will do it for us (or to us). Fellow appraisers, Please read this draft proposal for minimum national appraiser fees. I appreciate those who believe no one other than themselves should set fees, and I concur. Except, in the real world of today someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition. I’m interested in your meaningful, constructive feedback as well as comment & discussion here. For those that insist ONLY regional fees are practical, this same system works...
An Open Letter to the Valuation Profession from the Appraisal Foundation regarding the rift with the Appraisal Institute Value. Appraisers grapple with this concept daily as they analyze data and information to arrive at an opinion that is credible. Some information found is valid, some is tainted, and appraisers work diligently to separate the good from the bad to arrive at their conclusions – opinions that can withstand future tests. Likewise, The Appraisal Foundation (TAF; the Foundation) remains constantly attuned to what is going on in the valuation realm, conscientiously analyzing information and working to uphold the appraisal profession so its actions...
Cooperation between appraisers and multiple appraiser organizations wins the day in California! When is the last time you heard of a State bill that was already passed by both State Houses (Assembly & Senate) in any state, being quashed short of a Governor’s veto? Especially a “consent calendar” item that legislators automatically vote to approve for each other as a legislative courtesy. In less than two months? Let me share a quote from Rey Cano’s regular appraiser newsletter (www.Malibuappraisal.com). Rey, along with George St Johns, was an original co-founder of the California Coalition of Appraisal Professionals (CaCAP), where with full...
Background checks & third party relationships Appraisers, One of the recent thorns in appraisers’ sides has been the issue of background checks. A key reason for this is the Office of the Controller of the Currency (OCC) bulletin, which outlines the management responsibility banks must take when dealing with ‘third parties. Third parties include the AMC’s banks use to ‘manage’ their appraisal orders, and vendor appraisers. The bulletin puts the fear of God into bank Board of Directors. Since water runs downhill, the banks are telling AMCs that they must improve how they ‘vet’ appraisers on their panels. Many AMC’s are...
