Category: Customary & Reasonable Fees

A Journal Piece of Appraiser Independence (Part 2): Appraisal Independence Violated 2

Appraiser Independence Violated

A Journal Piece of Appraiser Independence (Part 2): Appraisal Independence Violated History is an important reminder to us all of what went wrong and what went right. When history is known we tend to skip the mistakes we made. We can either choose the right path for the wrong reason, the right path for the ‘right’ reasons and, we can take the wrong path in a similar manner. The MARKET needs to take the right path for the ‘right’ reasons. In years of late 1998 and 1999 several ideas were brought forth to a Forum filled with Individual Appraisers carrying...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Automated Valuation Models

Online Petition to Make a Difference in Customary and Reasonable Appraisal Fees 5

Customary & Reasonable Appraisal Fees

A Cost-Plus fee structure will allow the Customary and Reasonable Fee provision, a component of Appraiser Independence, to be more readily adopted. Fellow Professional Appraiser, I am asking you to take a moment from your busy day to PARTICIPATE in an important industry effort. That issue is referred to within Title XIV of the Dodd-Frank legislation as “Customary and Reasonable Fees”: CUSTOMARY AND REASONABLE FEE In General – Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

Questions Regarding Customary and Reasonable Fees? 9

Usual & Customary? According to Who?

Try this method of “price fixing” in any other business and see what happens! The “marketplace” usually sets what is considered “customary and reasonable”. Imagine asking attorneys to base their fees on what some government official (who knows nothing about their business) decides is “customary and reasonable”. It would NEVER EVER work, and should not be part of the appraisal (or any other) industry. It’s absolutely price-fixing which I always thought was illegal. The HVCC started all this focus on the appraisal industry and everybody is so busy trying to remake the appraisal industry, the banking industry quietly slips away,...

Appraisal / Appraisal News / Appraisers News / Customary & Reasonable Fees / Dodd-Frank Act / C&R Fees

Extinction of the Appraisal Industry - Image courtesy of Nujalee / FreeDigitalPhotos.net 23

The Imminent Extinction of the Appraisal Industry?

Late yesterday afternoon a bill was introduced in the House of Representatives that would alter the mortgage process and ultimately the way millions of Americans receive a mortgage. HR 1108 would eliminate the need for an appraiser to appraise a home prior to the funds being disbursed to the

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Technology

Appraisal fee study 6

Appraisal Fee Study – Louisiana

Louisiana Appraisal Fee Study The Business Research Center at Southeastern Louisiana University conducted an online survey of mortgage lenders with offices in Louisiana and licensed Louisiana real estate appraisers to collect information on typical residential real estate appraisal fees paid in Louisiana in 2012. Appraisal fee data were restricted to appraisal fees paid directly to licensed appraisers (i.e., not routed through appraisal management companies (AMCs)), per guidance of relevant federal regulations for determining “customary and reasonable” fees. Useable responses were received from 113 mortgage lenders located in 25 parishes (plus out-of-state) and 383 appraisers with primary offices in 38 parishes (plus...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

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Response to "A Wakeup Call for the Valuation Industry: Is anybody listening?"

RE: Richard Gilmore, ARA article – "A Wakeup Call for the Valuation Industry: Is Anybody Listening?" I would like to offer some comments regarding Mr. Gilmore’s article in the April 9, 2013 issue of Ag News. I also read most of the NAHB report – "A Comprehensive Blueprint For Residential Appraisal Reform" dated February 2013. I disagree with most of Mr. Gilmore’s comments regarding the NAHB report. The NAHB report lacks a realistic understanding of what is taking place in the real estate appraisal profession today. Most of what is commented on in the NAHB report has been required and/or in place for more...

AMC / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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Appraisal Advisor, a Real Estate Appraisal Technology Company, Launches Nationwide

Real estate appraisers find, rate, and manage clients using Appraisal Advisor’s new platform. Atlanta, GA – Tuesday, April 16 – Appraisal Advisor, LLC announced today the launch of an exciting new service focusing on helping real estate appraisers better evaluate and manage the clients, appraisal management companies (AMCs), and lenders that they do business with. Appraisal Advisor provides appraisers with instant access to client ratings and reviews, written by other appraisers, and gives appraisers an avenue to have complaints and non-payment issues be heard. Already boasting an unprecedented database of hundreds of thousands of individually-verified clients and thousands of reviews...

AMC / AMC Ratings / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Technology

NAIHP Promotes New Appraisal Rules on Capitol Hill 4

NAIHP Promotes New Appraisal Rules on Capitol Hill

NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

Evaluation Solutions ES Failure 2

Evaluation Solutions Failure

Evaluation Solutions, LLC: The Anatomy of an AMC’s Failure and Why Lender’s Should Care Last week, I had the pleasure of speaking to the Collateral Risk Network about lender oversight of appraisal management companies. With that exciting topic as my general theme, I chose to address the specific issue of AMCs failing to pay independent contractor appraisers for appraisals ordered by the lender-client (and also failing to pay agents and brokers for BPOs). This issue has been brought to the forefront of many appraisers’ minds and bank accounts by the recent failure of two large AMCs: National Real Estate Information...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

CoesterVMS Flat Fee Appraisal Structure Controversy 3

CoesterVMS Flat Fee Appraisal Structure Controversy

Lately, there has been some controversy surrounding the announcement of CoesterVMS implementation of a flat fee appraisal structure which went into effect on January 1. The announcement appeared on CoesterVMS Blog on January 7: CoesterVMS, a nationwide appraisal management company, has implemented the appraisal industry’s first ever flat fee model for residential appraisals. Under the flat fee model, which took effect on January 1, 2013, all conventional appraisals for mortgage lenders are priced at $450 while FHA appraisals are $475*. Customarily, appraisal management companies utilize a tiered fee structure, whereby prices are determined based on the property type or the...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

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