Category: Consumer Financial Protection Bureau

LREAB Response to FTC Allegations 15

LREAB Response to FTC Allegations

FTC seeking to punish LREAB for following federal regulatory mandates… BATON ROUGE, LA (May 31, 2017) – In an administrative complaint filed today by the Federal Trade Commission (FTC), it was alleged that the Louisiana Real Estate Appraisers Board (LREAB) had fixed the minimum price of residential real estate appraisals by enforcing the Board’s obligations under federal law to ensure that appraisers are paid customary and reasonable fees for their services. Bruce Unangst, Executive Director of the Louisiana Real Estate Appraisers Board (LREAB), said: “Respectfully, the FTC is just plain wrong. By issuing this legally faulty and factually incorrect complaint,...

Ocwen's Trouble May Mean More Business for Appraisers 3

Ocwen Is In Trouble

Could Ocwen’s trouble mean more business for appraisers? Ocwen Financial is in trouble with 22 States and the Consumer Financial Protection Bureau. Some states have issued a Cease and Desist Order, others like South Dakota are telling it like it is: “Ocwen does not possess the competence, experience, character, or general fitness required to permit Ocwen to continue…” Could this mean more business for appraisers? Will these issues be found in other lenders? How will the Real Estate and mortgage market be impacted? Time will tell. In the meantime, read all about Ocwen’s trouble on HousingWire here. In Other News:...

Preferred Appraiser, the Latest AMC Ploy 15

The Latest AMC Ploy

Oh what fun it is to become PREFERRED… Folks, From various sources I’m learning that you now have the outstanding opportunity to become a "preferred appraiser" with certain AMC’s. What does that mean…really? It means you will have assignments automatically assigned to you at a set (lower than C&R) fee and with a mandated report delivery date pre-selected. This process might even 'help you out' by also pre-scheduling the home visit with the borrower or RE agent for a certain day and time. It matters not that many of the assignments will be the left over highly complex junk properties...

Eliminate the Appraisal Subcommittee too! Appraisal Institute Effort to Eliminate the ASC 38

AI’s Effort to Eliminate the ASC!

Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...

The Partisan Battle to Eliminate Dodd Frank 15

The Partisan Battle to Eliminate Dodd Frank

Dodd Frank created the illusion… I had a different “take away” from the Housing and Insurance Subcommittee “Modernizing Appraisals” hearing. My impression was that there were two simultaneous hearings by the same people in the same place. There was the actual televised hearing with disparate prepared speeches, and then there was the real underlying reason for the hearing. The partisan battle to eliminate Dodd Frank. I try very hard to take a non partisan approach to the issues facing appraisers when writing about or for the American Guild of Appraisers (AGA). Obviously AGA is a union organization, though as I’ve...

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 38

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

Greed Takes Over With Next Loss of Memory 14

Greed Takeover Coming Soon

Basic greed and institutional memory I am amazed how many times in my lifetime I have seen the past repeat itself. Beginning in the 1970’s, I have witnessed one form of financial meltdown after another, each occurring almost precisely 10 years after the last. I once had a wonderful professor who explained that the seemingly inevitable repetition of the past was based on numerous, very different factors, but with two factors appearing in virtually every case. The two “alpha” factors are (1) basic greed and (2) institutional memory. Basic greed is when one group of people is willing to compromise...

We Need More Appraiser Drivers! 9

We Need More Appraiser Drivers!

Powerful ‘uncles’ gave us the vehicles, but we need more drivers! Stand up for yourself and oppose those things that are wrong in our own profession and the related lending industry. Oregon: Teach THEIR Board USPAP! Seriously. They were trying to fine people for not meeting turn times, as a USPAP violation! TWENTY FOUR PER CENT of the AARO (Government Regulatory Officials) members they contacted for advice ALSO thought the same way! …New Jersey, Minnesota, Illinois and how many others: Ongoing reports, and evidence, of punitive mindsets rather than protective of the public views. They are using fines to balance budgets…

FFIEC Requested Action on TRID - Imagecredit Flickr - Johannes Ahlmann 6

FFIEC Requested Action on TRID

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...

TRID Impact on Appraisal Fees 8

TRID Impact on Appraisal Fees

Appraisers, The Consumer Finance Protection Bureau (CFPB) has mandated new residential mortgage application and disclosure procedures, which take effect Oct. 3, 2015. Here’s a link to a brief article about this. When a consumer applies to a mortgage lender, the lender requests certain information from the consumer before the clock starts ticking in terms of ‘timing requirements’ on the consumer’s application. When the application is considered “complete”, the lender has 3 business days to provide the consumer with the Loan Estimate document. What’s of concern among lenders and appraisers is the speculated inability to change appraisal fees, which is disclosed...

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