Category: Dodd-Frank Act / C&R Fees

Appraisers Participation Needed - NMAC Tackling BPO & CU Issues - Imagecredit Flickr - Miles Heller 2

Appraisers Participation Needed – Tackling BPO & CU Issues

The appraisal industry was blindsided once again only this time by the AG’s office when they determined that the Real Estate Appraiser Board cannot regulate BPO’s. The New Mexico Appraiser’s Coalition and the Rio Grande Chapter of the Appraisal Institute sent a joint letter to the Appraisal Board prior to a hearing that was held in January to discuss the BPO language in the Appraiser Act. Although we feel we provided enough information to guide the Board, the Attorney General Representative at the meeting made the determination that the Appraisal Board had no jurisdiction over the BPO product. Even though...

AI / Appraisal / Appraisal Institute / Appraisal News / Appraisal Organizations / Appraisers News

Appraiser-Client Relationship - Imagecredit Flickr - Dennis Hill 15

Don’t You Value our Relationship?

Relationships, we all have them.  And despite the efforts of Dodd Frank to destroy them, we have somehow managed to keep them. A big bank that I had a great relationship dropped me because their portal system decided there were too many appraisers last year and left me hanging. No orders for a year. Now they’re busy and want me to do appraisals. Great! But between the portal fees, underwriting charges, title surpluses, software charges, destination charges, taxes, etc. the fee works out to be substantially lower than most work I have. They asked me “don’t you value our relationship?”. I replied where...

AI / Appraisal / Appraisal Institute / Appraisal News / Appraisal Organizations / Appraisers News

AMC Regulation Rule Finally Published in the Federal Register - Imagecredit Flickr - Steven Lilley 1

Federal Register: AMC Final Rule

AMC Regulation Rule Finally Published in the Federal Register Appraisers and others, On June 9, 2015, the Federal Register published the new AMC Registration and Regulation Final Rule: The OCC, Board, FDIC, NCUA, Bureau, and FHFA (collectively, the Agencies) are adopting a final rule to implement the minimum requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) to be applied by participating States in the registration and supervision of appraisal management companies (AMCs). Thanks to Bill Garber, Appraisal Institute Director of Governmental Affairs, for sending me this info today. I first wrote & sent info...

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

1st Enforcement of C&R Fee Provision Louisiana Makes History - Imagecredit Flickr - Roland Tanglao 5

Louisiana Makes History – C&R Fee

First Enforcement of C&R Fee Provision: Louisiana Makes History Nearly five years after Dodd-Frank set forth rules regarding Customary & Reasonable fees (C&R) for appraisers, an agreement last week between a state board and an Appraisal Management Company (AMC) is the first evidence of enforcement. The bottom line for appraisers is that they may be finally on their way back to customary and reasonable fees. On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) issued a Stipulations and Order Memorandum (SOM) wherein Coester Appraisal Management Group, also known as Coester VMS, offers no admission of guilt but agrees...

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

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint - Revised Press Release - Imagecredit Flickr - Nic McPhee 1

LREAB Resolves AMC Complaint – Revised Press Release

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint Baton Rouge, LA – – On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) approved entering into a “Stipulations and Order” with Coester VMS Appraisal Management Group. The Order will resolve a pending complaint that alleged that Coester violated Louisiana law that requires AMCs operating in the state to “compensate appraisers at a rate that is customary and reasonable for appraisals being performed in the market area of the property being appraised, consistent with the presumptions of compliance under federal law” (La.R.S. § 3415.15, La. Admin Code. tit. 46,...

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

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 16

AMC Fined for Reasonable & Customary Fees Violation

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees As a result of a thorough investigation conducted by The Louisiana Real Estate Appraisers Board (LREAB), an adjudication hearing for an appraisal management company was held to determine if that firm is following the laws and rules pursuant to minimum reasonable and customary fees, as required by the Dodd/Frank Act and Louisiana laws and Appraisers Board rules. The case alleges the appraisal management company Coester VMS was not compliant with the state’s AMC laws and...

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

Unintended Consequences & Regulatory Issues Facing the Real Estate Appraisal Profession 4

Unintended Consequences of the Dodd-Frank Law and Potential Remedies

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...

American Society of Appraisers / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / ASA

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Evolution of C&R fees – Alter Your Thinking

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...

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

North Carolina Proposed Law on Reasonable & Customary Appraisal Fees 7

NC Proposed Law RE R&C Appraisal Fees

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...

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

Texas AMC survey 2

Texas Appraisers and AMC 2015 Survey Report

The Texas Appraisers and Appraisal Management Company 2015 Survey Report In January and February 2015, the Texas Appraisers and Appraisal Management Survey surveyed a total of 1,421 Texas appraisers and 55 appraisal management companies doing business in the state of Texas. The questions in the survey were specifically designed to achieve the following: Clearly distinguish between the fees paid to appraisers by Appraisal Management Companies (AMCs) and fees paid by non-AMC clients for residential appraisals. Capture any difference in fees paid by property type: single family, condominium, size or square footage, or other factors. Capture the impact on fees by market area...

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

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