For well over a year, the Columbia Society of Real Estate Appraisers and five other nonprofit appraiser groups have been working on an industry paper entitled Regulatory Issues Affecting the Real Estate Appraisal Profession (subtitled: Unintended Consequences of the Dodd-Frank Law and Potential Remedies). The paper is aimed at informing lawmakers of some of the unintended consequences of the Dodd-Frank law as it relates to appraisers and consumers. We hope that lawmakers will address and correct some of the issues brought to light in this paper. The Letter Over the past year, a select group of professional appraisal organizations have...
AMCs procrastinated or missed the renewal period We started registering AMCs about this time back in 2013. It was a slow roll from the nascent 9 applications received in March of 2013 to a peak of 42 applications received in August 2013 just ahead of the deadline to register. Since that time the number of AMCs in Illinois has ebbed and flowed. At one point we had 192. As of this writing, we stand at 155. Nationwide there are less than 700 AMC entities. The universe is small. We’ve already completed our first renewal that ended on December 31, 2014. Like...
GLA in your appraisal reports being questioned Appraisers, today (4/30/15), Freddie Mac released a document showing Warning and Fatal codes that will trigger if certain items are found in your reports sent to Freddie Mac through the Uniform Collateral Data Portal (UCDP), as of June 30, 2015. In 25 pages of codes, only 4 are ‘fatal’ and those are for items you should not be overlooking. See the PDF below and take a moment to look over the document. The very first ‘warning’ code is this one, which has two variations: FRE1001 The gross living area for the subject property ([GLA] sf)...
Many residential appraisers we insure and several appraiser organizations have contacted us in the last few days about an appraisal management company’s new requirement that their panel appraisers upload a PDF copy of their appraisal workfile for each assignment they perform. The AMC is LenderVend, LLC and, according to its website, it is affiliated with mortgage lender Provident Funding. We understand that LenderVend’s requirement imposes an additional burden on appraisers. We’ve also heard firsthand from appraisers about the anxiety the policy is creating because of the unknown uses to which the workfile may be put by the AMC. As is the case with any peculiar...
Should You Include Your Workfile With Your Submitted Appraisal Reports? Appraisers, On several forums frequented by real estate appraisers, there has been recent discussions about a particular Appraisal Management Company (AMC) owned by a lender who is requiring appraisers to include their ENTIRE WORKFILE with every appraisal report submitted (as of 5/21/2015). The AMC is LenderVend, owned by Provident Funding. One reason why this has come to the forefront is because Provident Funding has had to buy back numerous loans due to alleged faulty appraisals and other underwriting issues. So by demanding the appraiser’s workfile, they are attempting to protect themselves...
I was recently asked by a local lender to appraise 14 vacant lots. Though the lots were all quite similar, 14 separate appraisals were needed (obviously, a large discount was given for the multiplicity). Once a value was established for each individual lot, the lender came back and now wanted a ‘bulk value’ for 10 of the lots. Hmmm. That certainly changes things. Per USPAP in fact, we now have a new assignment. As I inquired to the bank and got more information, it was clear that I was out of my element. The lender did not just need a total...
Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...
It is merely a SALE… Appraisers, Something’s been gnawing at my craw ever since January when FNMA’s wonderful Collateral Underwriter (CU) was unleashed to the world. And before that, when FNMA’s Appraiser Quality Monitoring (AQM) process was introduced to judge the work of appraisers. No one else has written about this. No one has even mentioned it. So I will: It has to do with the word “Comp” which is used liberally by Fannie Mae (FNMA). What exactly is a “Comp?” In FNMA’s world, it’s any property that they obtain, either by their vast AVM process which examines millions of...
North Carolina Proposed Law Would Address Reasonable and Customary Appraisal Fees North Carolina’s House Bill 577, introduced April 2, 2015, would seek to address reasonable and customary appraisal fees. Some of the proposals in the Bill would: Require the NC Appraisal Board to publish a “schedule of customary and reasonable rates of compensation for appraisals based on the market area where the real property is situated.” Establish rates by fee studies that would exclude assignments ordered by known appraisal management companies. Require rates to be “measured by the net compensation amount received by the appraiser.” Allow for payments above the...
How do we move to be more of a Red Box? I stopped at a Sheetz to get gas. As I was standing there I noticed a Red Box Machine which had a steady flow of traffic. Next door was an old closed Block Buster Video. Hmm… When my kids were little it was a big treat to go to that Block Buster and rent a movie. We had to wait in line 5 to 10 minutes and now it’s closed. But the Red Box machine is steadily pumping out DVDs. So I got to thinking. What are appraisers? Are we...
