The CFPB has ordered Amerisave and Novo to pay $14.8 million… The Consumer Financial Protection Bureau (CFPB) announced Aug. 12 that it fined mortgage lender Amerisave Mortgage Corp., its affiliate, Novo Appraisal Management Company, and the organizations’ collective owner, Patrick Markert, $19.3 million for allegedly luring prospective borrowers with misleading interest rates and trapping them with inflated appraisal fees. The CFPB claimed that the lender and its affiliated AMC violated the Truth in Lending Act and Real Estate Settlement Procedures Act by enticing tens of thousands of borrowers with deceptive advertising and then illegally overcharging them for third-party services. The...
Fannie Mae’s Murphy stated that over the past year, the GSE had been focusing on “quality” and “condition” ratings of comps used in multiple appraisals by the same appraiser and found many cases where the appraiser has changed the quality and/or condition ratings on the same comparable from appraisal to appraisal. Now, based on the examination of the Uniform Appraisal Dataset (UAD) data, Fannie Mae’s focus for the next 12 months will be on adjustments. The data indicates that many appraisers are not using…
80,500 Total number of active real estate appraisers CHICAGO (July 31, 2014) – The number of active real estate appraisers in the United States fell less than 1 percent in the first half of 2014, the Appraisal Institute announced today, lower than the average annual decrease of 2.6 percent over the past six years. Research conducted by the nation’s largest professional association of real estate appraisers found that as of June 30, the total number of active real estate appraisers in the U.S. stood at 80,500, down from 81,050 on Dec. 31, 2013. A broader analysis suggests the rate of...
Some stats on Appraisal Management Companies (AMCs) Most AMCs are small companies. 86% have annual gross revenue less than $10 million. Conversely, 13% have annual gross revenues of over $50 million. AMCs are more frequently adopting a “cost plus” pricing model for their services. This means they charge a separate fee for their service and are transparent about their fees paid to an appraiser. (Note: Arizona Appraisal Statute requires appraisers to disclose the fees they have been paid by an AMC in the Scope of Work section of the appraisal). 35% of the AMCs surveyed are headquartered in the western...
USPAP Violations… This is a list of USPAP violations most commonly encountered by the Texas Appraiser Licensing & Certification Board’s staff appraiser-investigators when investigating complaints filed with the Board. This list of violations is given for informational purposes only and does not constitute legal advice or instructions on how to properly comply with USPAP or properly complete an appraisal assignment. Most Commonly Encountered USPAP Violations: Sales Comparison Selection of Comparable Properties. Failing to select and/or support the selection of comparable sales using recognized methods and techniques. Examples include: Leaving the subject’s neighborhood when sales data is readily available in the immediate neighborhood; Searching by...
When and how BPOs and CMAs may be performed by brokers & managing brokers Legislation that would clarify several aspects of an Illinois law governing broker price opinions and comparative market analysis has passed the state legislature and currently is under consideration by Gov. Pat Quinn, the Appraisal Institute reported July 23. SB 3044 adds definitions of both BPOs and CMAs to the state’s Real Estate Appraiser Licensing Act and its Real Estate Licensing Act, and clarifies when and how BPOs and CMAs may be performed by brokers and managing brokers. The bill was sent to Quinn June 27, and...
Freddie Mac will host a webinar June 26 that will highlight upcoming changes to its multifamily appraisal requirements. Freddie’s new requirements, which take effect July 1, will address tying together an appraiser’s multifamily data with their conclusions. Examples include: Tighter guidelines around the use of property condition assessments and environmental report drafts; Discussions around local market data in the capitalization rate analysis; Elimination of net income multipliers or adjustments to net operating income in the Sales Comparison Approach; Supplemental discussion of the risk of reassessment of property taxes including a quantifiable chance of a reassessment; and Documentation of the number...
Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...
The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...
Recently a particular engagement letter format has been circulating amongst residential appraisers from several nationally chartered banks. Aside from the usual intended use and exposure time boilerplate requirements there are several new problematic inclusions. Personal Property All personal property transferring in a purchase transaction must be described in the appraisal whether or not it was listed in the sales contract. Any client is free to ask for a shopping list of tchotchkes, but if an appraiser is appraising an abandoned residence with piles of junk laying everywhere…they couldn’t afford my time to sift through it all like in an episode...
