Category: Appraisal

The Harassment Campaign Against Mom-and-Pop Appraisers 12

Stoked by HUD, Cottage Industry Shakes Down Mom-and-Pop Appraisers

The harassment campaign benefits a number of odd bedfellows: the housing lobby, which wants unfettered access to federal funds and taxpayer-backed mortgage guarantees through Freddie, Fannie and the FHA – they see appraisals as an unnecessary bottleneck. A firm called Mizrahi Kroub is the largest filer of so-called “digital Americans with Disabilities Act lawsuits.” The New York law firm files about a quarter of all such cases nationwide, according to a provider of web-accessibility services. The firm, which employs nine lawyers, has brought more than 1,100 web-accessibility cases against small businesses for missing alt-text, incorrectly formatting lists or providing unclear...

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations 95

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit. The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies...

NHFA-HUD misleading billboard ads 26

Misleading Ads Sow Mistrust

These misleading ads are sowing seeds of mistrust in a time-tested profession. The National Fair Housing Alliance (NFHA) has recently launched a concerning campaign of poster ads, billboard ads, and magazine ads that falsely accuse home appraisers of basing their valuations on the personal characteristics of the homeowners or prospective buyers, rather than solely on the objective merits and features of the property itself. This is a deeply misleading and unjust narrative that undermines the integrity of the appraisal profession, which is founded on the core principle of providing an independent, impartial assessment of a home’s value. Appraisers are highly...

County Assessors' Standards - AVM Final Rule Guidance 16

County Assessors’ Standards | AVM Final Rule Guidance

County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach.  The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...

The Censorship Campaign - Housing Inflation Exposed 29

Objectionable Valuations Become Hate Speech, Inflating Home Prices

The censorship, scapegoating and sidelining of appraisers has done real damage to borrowers and the purchasers of bonds…  Attacks on free speech are on the rise in the English-speaking world. A bill introduced in Canada to thwart online “anarchy and lawlessness” would create a Canadian Ministry of Truth empowered to punish authors Ottawa politicians find problematic. In response to the worst rioting in Britain in years, about 4,000 people have reportedly been jailed for online thought crimes. U.K. Prime Minister Keir Starmer has vowed to prosecute anyone his government believes is whipping up people’s emotions on the Internet. There’s even...

Fight Unfair AMC Practices - Leverage State Authorities 30

Fight Unfair AMC Practices – Leverage State Authorities

Alarmed by predatory practices among AMCs, a peer has drafted letters urging appraisers to call on state authorities to address unfair AMC conduct and potential regulatory violations.  As appraisers, we have faced an ongoing challenge with Appraisal Management Companies (AMCs) offering fees that are well below the customary and reasonable rates for standard appraisal assignments. This practice has created a troubling trend of “bid wars” where AMCs pit appraisers against one another, driving down fees to unacceptably low levels. In response to this issue, a peer has provided two draft letters that can be easily modified and used by other...

Insights from CFPB's Public Comment Period 53

Insights from CFPB’s Public Comment Period

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

Lack of Fee Transparency: Exposing the AMC Exploitation 71

Lack of Fee Transparency: Exposing the AMC Exploitation

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge.  Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

72

Accurate Appraisal Underreporting

The HousingWire article highlighting that only 40% of homes sold include an “accurate” appraisal, as defined by the Corporate Settlement Solutions (CSS) report, is deeply problematic and indicative of a concerning lack of understanding around the appraisal process. The report cited from CSS, analyzed appraisal data across 10 states in the East Coast and Midwest, finding that only around 40% of home sales included an appraisal that was within $2,500 of the final sale price. This is being presented as evidence that the vast majority of home appraisals are inaccurate. Appraising a home’s value is an inherently complex endeavor, with...

Key Part of USPAP Not Available from TAF 14

Key Part of USPAP Not Available from TAF

this is a colossal failure on their part – to have a key document on BACKORDER until a month from now, or longer!  Appraisers, I have a print copy of the current USPAP, but need/want a PRINT copy of the AO/FAQ Reference Manual, which TAF decided to make into a separate document for this version at a cost of $75. I prefer the printed versions, rather than the PDF so I can read it and use a highlighter for key items. I went onto the TAF web site on July 17, 2024 to order the document, and found this: In...

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