Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...
The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...
REASONABLE needs to become the appraiser’s operative word Appraisers, It’s time to grow a pair as some people say, or to stiffen the backbone, and quit caving in to the low ball fees being offered by some in this crazy “industry.” Another true statement is “you are what you are worth”. If you, as an business person, only know how to say yes to low fees, you won’t be worth anything higher to the majority of clients. Further, your self image and actual net worth are negatively impacted. You cannot expect to earn a certain income, then wonder why you gave yourself...
Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...
Dear Appraiser Colleagues, Awhile back, you responded to a request from VaCAP to supply your e-mail address to participate in an upcoming Customary and Reasonable Fee Survey to be conducted by the Virginia Center for Housing Research and the Virginia Tech Program in Real Estate. This communication is to notify you of the survey’s eminent release. Please look for it to be sent to you via e-mail in the next couple of days. Your participation in the survey is vital to the success of this endeavor. Please take the few minutes necessary to complete the survey; it should only take...
Appraisers to be paid within… It is all-too-rare that we hear positive news regarding the appraisal profession. There is an awful lot of complaining that goes on, most of it justifiable, but little good news that gets shared. Part of the problem is that there is no central source for information regarding our profession which appraisers might utilize in order to find out what is going on across the country and affecting our profession, and could be used to enhance our industry and our citizens in our own state. From what I have seen, most of any good news is being...
The good appraisers are leaving mortgage appraising as fast as they can. Thus far the housing industry has been applying “Band-Aid” solutions to the bigger real estate crisis. There are several problems going on at the same time, all contributing to the big picture, which is bleak to say the least. One true crisis in the real estate industry is an “information crisis.” This information problem, trickles down to appraisals, lenders, and ultimately, mortgage investors. Standardization, national guidelines, and disclosures are the only way back from this nightmare (i.e. the RESPA disclosure. One fee on the good faith estimate for...
In March, I once again traveled to Modesto, CA, and attended the Annual Spring Conference of the Appraisal Institute’s Northern California Chapter. This month, I will share some useful and interesting information from the presentations. The conference focuses on the California market, but many of the presenters also covered topics related to the national market. The first session was “State of the Appraisal Profession”; the speaker was Lance Coyle, MAI, and SRA who is national president-elect of the Appraisal Institute. He started by giving a brief history of the profession and pointed out that significant changes came to the profession...
A group of Real Estate Appraisal experts committed to the preservation, protection and enhancement of the appraisal industry has formed the Appraiser Prosperity Coalition (www.AppraiserProsperity.com), a merger of industry insiders and government affairs professionals dedicated to fighting for the legislative and regulatory changes needed to rebuild the industry in the wake of damaging legislation. As you know, in an effort to remove value pressure from Real Estate Appraisers, the Dodd-Frank law affirmed a move made by the Home Valuation Code of Conduct to transfer most real estate appraisal ordering power from the hands of the 250,000+ Loan Officers in this...
A Journal Piece of Appraiser Independence (Part 1): Where Do We Go From Here? Buyer Beware! Where is the Value? (PART 1) In the years of 2007/2008, the ideologue of, “Appraiser Independence” had become popular for the real estate market’s economic agents and the processes it relies on to function properly. The idea gained respect, due to the perseverance of Real Estate Appraisers carrying out their Independence, during the decade of 2000-2010. The Home Valuation Code of Conduct (HVCC) was introduced according to prevailing design and initiative: the advancement of a market in need for an inspired and renewed sense of...
