File the complaint against the AMC yourself OR Forward the engagement letter to VaCAP to file on your behalf. At the recent Virginia Appraisal Board Meeting on Wednesday June 28th, a discussion occurred about Appraisal Management Companies prohibiting appraisers from including their invoices with the appraisal report. The overall consensus of the Board Members was this practice could be a violation of Virginia Appraisal Management Company Statute § 54.1-2022 B. “B. The appraisal management company shall not prohibit an appraiser from disclosing in the appraisal report the actual fees charged by an appraiser for appraisal services, and shall otherwise comply...
1. A Call to Comment has been issued. 2. VA is looking for Appraisers. 3. AMC Disciplinary Action Snowballs into Multiple States… A Call to Comment has been issued. The FTC is asking for public comments on the consent decree by the Louisiana Real Estate Appraisal Board. The time line to comment is short and ends on July 22, 2021. VaCAP asks each of you to take a few minutes and read the consent decree as well as the analysis provided by the FTC before commenting. The link for the Federal Register that contains all the information can be found...
“If you don’t have a seat at the table, you are on the menu…” Would it be misleading to disclose you performed a personal inspection of a property done with significant appraisal assistance in which you relied on supported demographics? Well maybe… The Appraisal Foundation has issued a discussion draft to answer this question and others similar to it and wants your opinion. Now we understand that some of you will comment about what’s the point and some will state they don’t have time to participate; others will simply ignore it all together. Someone once said “If you don’t have a seat...
Why FHFA thinks the GSE’s should be even discussing appraisal processes is a question that needs to be asked of FHFA… Appraisers have let others dictate many things in our profession. It is time to stop the trend… How about 20 questions? The Federal Housing Finance Agency (FHFA) has 20 questions for you. Well, actually it is only 19 questions. The FHFA is the organization of the Federal Government that oversees Fannie and Freddie. They want feedback on how the GSE’s should move forward with appraisal policy, risk and appraisal processes. Now why FHFA thinks the GSE’s should be even discussing appraisal processes...
CFPB is moving forward with proposing to eliminate the Debt to Income requirement… Appraisers, prepare yourself for what we are about to share. The short sighted proposal is simply nonsensical from every angle. The Consumer Financial Protection Bureau wants to eliminate the Debt to Income requirement on Qualified Mortgages. You may recall this was proposed a while back and most of the profession objected strongly. Letters, emails and phone calls were made and this absurdity went away. Earlier today CFPB Director, Kathy Kraninger announced the CFPB is moving forward with proposing to eliminate the Debt to Income (DTI) requirement and...
Rumor has it there are several Virginia Real Estate State Appraisal Board disciplinary cases against appraisers revolving around hybrid appraisals… Some are for and some are opposed. It is a business decision on which types of assignments you choose to accept. If you choose to complete a hybrid or bifurcated appraisal, you need to pay attention and ask yourself a few questions. Is the fee I am receiving for completing this assignment reasonable for the scope of work I must perform? Notice the term customary was not used as these products are new and there is no customary fee YET....
It seems holding the appraisal management companies responsible for the hybrid inspection is the best option. The thinking was they choose, engage and pay the inspector. The Virginia Real Estate Appraiser Board met for its quarterly meeting on July 30, 2019. We are happy to report CoesterVMS no longer has a license to operate in Virginia. The Board voted to accept the consent order accepting the voluntary surrender of his license. The Board also passed a motion to draft legislation to be introduced into the General Assembly giving the Board regulatory control over the hybrid inspection and those individuals that...
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...
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,...
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...
