Category: Dodd-Frank Act / C&R Fees

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REALTOR® & Appraiser Interaction Under Dodd-Frank

A common complaint among REALTORS® in virtually all of Michigan is that many residential deals are failing because the home will not appraise at a value that permits the buyers to finance the purchase and close on the home. Many REALTORS® take the position that many of these properties do not appraise because the appraiser is not “geographically competent.” In other words, the appraiser is from out-of-town, unacquainted with the area in which the appraised property is located; thus, fails to learn or uncover various factors that would substantially change the valuation of the property. The question is then posed...

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Reminder to States regarding changes effective July 1, 2013

As a reminder to State Appraiser Regulatory Officials, effective July 1, 2013, the Appraisal Subcommittee (ASC) will formally incorporate new requirements into its State Compliance Review process.  As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of2010 (Dodd-Frank Act) amendments to Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (Title XI), and in accordance with Bulletin No. 2011-01 issued by the ASC on March 18, 2011, the ASC will formally incorporate the following requirements into the State Compliance Review process beginning July 1, 2013: Reciprocity:  In order for a State’s appraisers to...

North Dakota AMC law 1

North Dakota Governor Signs AMC Law

AMC Law in North Dakota North Dakota became the 37th state to enact a comprehensive law requiring the registration and oversight of appraisal management companies on April 12 when House Bill 1389 was signed into law by Gov. Jack Dalrymple. The law takes effect on Jan. 1, 2014. Under the new law, entities involved in the residential collateral valuation process must register with the North Dakota Real Estate Appraiser Qualifications and Ethics Board if they oversee a panel of more than 15 independent contract appraisers in North Dakota or 25 or more nationally. Entities that exclusively employ appraisers on an...

ASA Letter opposing Bill A3781 2

ASA Letter Opposing Bill A3781

Letter from ASA Opposing Bill A3781 Abolishing the NJ State Appraisal Board and Transferring Control to the Real Estate Commission Assemblyman Giblin: The American Society of Appraisers (ASA), the largest multidisciplinary professional appraisal organization in the United States, is writing to express strong opposition to Assembly Bill 3781, which would abolish the New Jersey State Real Estate Appraiser Board and transfer the regulatory oversight of appraisers to the State Real Estate Commission. This bill would weaken the overall regulatory scheme applied to real estate transactions and its myriad parties at a time when new federal and federally-mandated state regulations are...

URAR pandoras box 0

URAR Form Ambiguities and Liabilities

Revisiting The Fannie Mae/Freddie Mac 2005 URAR Form Ambiguities and Liabilities It has been eight years since the URAR form was revised. From 2005 to mid-2008, the real estate market experienced a boom and a bust the likes of which we have never seen before, and we are finally seeing a slow recovery. Also during this period, the economic recession and poor lending practices lead to new regulations in both the appraisal and banking industries. Based on the new regulations, Fannie Mae/Freddie Mac mandated appraisers to add more information to the URAR form. As of March 2009, the Market Conditions...

ASC letter RE Launch of the 0

Appraisal Hotline Operations Details

Appraisal Institute Wants Details on Appraisal Hotline Operations The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 12 to the Appraisal Subcommittee asking that it make its proposed protocol for operating the “appraisal hotline” available for public comment prior to its March 29 implementation. In the letter, AI and ASFMRA said that while the concept of a hotline is sound, there exists almost no understanding among state appraiser regulatory officials, practicing appraisers and real estate and mortgage professionals as to how the hotline would function or even of its intended purpose....

Appraisal Complaint Hotline Usage 0

Appraisal Complaint Hotline Usage

Four Reasons Why ASA & NAIFA Urge Appraisal Subcommittee to Delay Rollout of National Appraisal Complaint Hotline On February 6 ASA, along with the National Association of Independent Fee Appraisers (NAIFA), sent a letter to the Appraisal Subcommittee (ASC) urging them to delay the planned March 29th implementation of the national appraisal complaint hotline, as required by the Dodd-Frank Act. In pushing for the delay, ASA and NAIFA pointed to several issues regarding the hotline’s formation: That the appraisal complaint hotline was created in a closed process, without adequate stakeholder exposure or input; The hotline, as proposed, violates Congress’s intent...

Three Ways to Reverse the Mass Exodus of Appraisers - Hire a Trainee 3

Hire & Reverse the Mass Exodus of Appraisers

If you are doing too much and not being paid enough, you are a PERFECT candidate to hire and train a new appraiser.  Three Ways to Reverse the Mass Exodus of Appraisers I was recently in Texas at yet another appraisal conference. The man who was speaking asked everyone to stand up. There were approximately 140 appraisers in the room. He then asked for those under 30 years of age to sit down. About five people did. He asked those under 40 to sit down. About 10 more did. Under 50. About 25% of the room was now sitting. Finally,...

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Is the Appraisal System Broken?

John Brenan, The Appraisal Foundation, and Melissa Cohn, The Manhattan Mortgage Company, discuss on CNBC, whether the home appraisal system is broken after the Dodd-Frank Act. …complaints are skyrocketing and many appraisers are getting low or even failing grades now. Why is this happening?

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...

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