Category: Dodd-Frank Act / C&R Fees

Appraisal news for real estate appraisers and real estate professionals regarding Dodd -Frank Act and Customary and Reasonable appraisal fees. News relating to the Appraisal Industry.

Dear Representative, FNMA Has Gone Rogue! 87

Dear Representative, FNMA Has Gone Rogue!

Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending purposes is nothing more than wanton recklessness that could have serious repercussions in the future. The truth of the matter is that appraisals are an essential part of any mortgage transaction and should not be taken lightly or eliminated without due consideration. Without them, there can be no assurance as to whether a homebuyer will get what they pay for or if lenders will make bad investments with their money. In short, waiving/eliminating property appraisal requirements puts everyone at risk...

Look in the Mirror 15

Look in the Mirror

The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is a powerful statement that can evoke a range of emotions and reactions from individuals, from contemplation to defensiveness. At its core, the phrase is a call to examine oneself honestly and objectively. It asks us to step back from our assumptions, biases, and preconceptions and consider our behavior, choices, and beliefs in a critical light. When we take a look in the mirror, we are forced to confront our flaws and shortcomings, but also to recognize our strengths and achievements....

Opportunity to Work for Free is Not a Plan 73

‘Opportunity’ to Work for Free is Not a Plan

I gave this ‘opportunity’ further critical analysis in terms of time spent versus the fee income potential.  Appraisers, I’d like to disclose a personal ‘opportunity’ that was presented to me last fall, early winter. A company with AMC roots was, or is, recruiting people to become “property inspectors” with the resulting reports potentially fed to other appraisers who do HYBRID, or maybe even DESKTOP reports. The GSEs never intended the DESKTOP report to incorporate separate ‘property inspections’ from a hired third party, but that’s been the evolution because they just look the other way. Last fall, due to the slowdown...

"Valuable" Advice From an AMC - Valuation Connect 57

“Valuable” Advice From an AMC

The person who espouses this super valuable ‘advice’ does not have an appraiser’s license… Appraisers, if you think I’m serious about the message subject line, please reconsider! It’s time to actually call out an AMC who’s encouraging appraisers to ‘lower their fee’: Valuation Connect This outfit sent out a ‘newsletter’ to appraisers, part of which says this: “My advice would be to make adjustments based on the market. Some examples in a slow market would be adding a new county or zip code to your coverage area, lowering your fee for a product, or adding a new product to your...

FastApp AMC Alleged Violations of Appraiser Independence Requirements 52

Fastapp AMC Alleged Violations of AIR

The following court documents in the case Naftali Horowitz v. [xxx], Fastapp AMC founder v. Fastapp AMC president, confirm what appraisers have been saying all along, that if you want high-volume AMC work, you have to lower your fees to 1980’s level, have 24 hour turn times, and, above all, be a number hitter. Horowitz, Fastapp founder, filed a lawsuit in New York court on January 31, 2022 against defendant to, among other things, remove the defendant as an officer and director of the Company because, when he brought her on as shareholder in 2020, he claimed that she made...

Appraisal Management Companies Take a Sizable Cut of the Appraisal Fee 97

AMCs Take a Sizable Cut of the Appraisal Fee

It still proves my point: Appraisal Management Companies take a sizable Cut of the appraisal fee… It was March 28th, 2018 that I wrote my very first blog post entitled “What’s not in your wallet?” where I went into great detail about how Appraisal Management Companies or AMCs get paid and how the consumer is not aware of the fact that the AMC is taking much of the fee while finding the cheapest and fastest appraiser. In that blog post, I gave many examples of the abuse appraisers and consumers are absorbing by these Appraisal Management Companies. How one borrower...

What Is My Incentive to Take on Trainees? 22

What Is My Incentive?

Why would I bother taking on the added risk of an inconvenient process? Where is my incentive again? As an appraiser, I have to ask (seriously) why should I care if the profession has a shortage of skilled appraisers? Logic dictates that If there is a shortage, then I will remain busy. Even if waivers (another ruse to eliminate appraisal work) increase, I’ll be busier with fewer appraisers. Especially with so many of them “trained” under PAVE or PAREA programs. If there is an adequate supply of appraisers, then users of appraisals will continue to seek cheaper alternatives from them...

Georgia State Appraisal Board Tables Proposed Rule to Eliminate C&R fee 8

Proposed Rule to Eliminate C&R Fee Tabled

Yesterday morning, I attended the Georgia state appraisal board hearing on the proposed rule to eliminate the C&R fee law they have in place. You know, the one that is similar to the one in Dodd-Frank. The Georgia appraisal board apparently is being investigated by the FTC for their law. They thought that the FTC vs the Louisiana case was a ruling in favor of the FTC when in fact it was not, and wanted to avoid any sort of notion that they were price fixing or of anti trust. The board received letters from appraisers and others in the...

Violating Appraisal Independence - Appraiser Intimidation & Coercion 12

Violating Appraisal Independence Through Harassment, Intimidation & Coercion

It shall be unlawful… to engage in any act or practice that violates appraisal independence… Appraisers, I have written the info below, which you may use if you desire to send to your clients and local real estate offices. It’s time for all appraisers to stand up to this kind of very adverse behavior, done by and promoted by many real estate brokers/agents across the US. I have been chastised multiple times by brokers, and in one instance that I know of, was excluded (by the lender who told me) from doing another assignment when I didn’t appraise a prior...

Support your fellow appraisers in Georgia 30

Is Georgia Going Rogue?

VaCAP has learned the Georgia Real Estate Appraisal Board is considering rescinding rule 539-1-.23. This rule is the customary and reasonable fee requirement to appraisers from appraisal management companies. The matter will be decided at a 9:30 AM Sunday July 17, 2022 meeting. From the Georgia Real Estate Commission and Appraisal Board: RULE 539-1-.23 Appraisal Management Companies Purpose: In light of the recent decision and order In the Matter of Louisiana Real Estate Appraisers Board Before the Federal Trade Commission of the United States and to avoid even the appearance of anticompetitive conduct or the unreasonable restraint of price competition...

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