Category: Dodd-Frank Act / C&R Fees

iMortgage, the Dollar Bidding Company, Sues LREAB for Antitrust Violation 7

LREAB Hit With an Antitrust Lawsuit

…everyone knows that iMortgage / Single Source is the “dollar bidding” company. They send out appraisal requests at $1.00 and ask everyone to provide their fee… The Louisiana Real Estate Appraiser Board has been hit with another legal battle. This time, iMortgage, operating under the name Single Source has filed suit against the Louisiana Real Estate Appraisal Board claiming a violation of antitrust laws. This suit mirrors that of the FTC, which is currently paused by the Fifth Circuit Court. In the suit, iMortgage claims rules created by the Louisiana Real Estate Board, which consists of market participants, set appraisal...

Appraisal Fee Transparency Falls Short - Appraisal Complexity Ignored 9

Appraisal Fee Transparency Bill Falls Short

No system that continues to allow (or limit) defining appraisal complexity to the lender or AMC will ever achieve reasonable, or fair compensation for the appraiser…. We need to do much better than “half a loaf” in our appraisal legislative efforts. Especially when that half loaf does no more than enshrine continued price-fixing by lenders; with the support & blessing of REVAA… WorkingRE published news of recent House of Representatives action. The Bill addresses consumer disclosure of AMC fees among other issues. While the American Guild of Appraisers applauds the efforts of those that worked in good faith on this,...

Game Over ServiceLink - AMCs Appraisal Schedule Fees Made Public! 61

Game Over ServiceLink

Now that ServiceLink fee schedule, indicating fees paid to appraisers and fees charged to the lenders, has been released to the public, there is absolutely no reason for in camera review… We are sure you have heard the old saying what goes around comes around, right. Well, here we are again; The FTC vs Louisiana Real Estate Appraisal Board case has been brought back into the spot-light. As you may recall, the LREAB filed a civil case against the FTC in attempt to stop the case against them. That case was denied due to lack of jurisdiction. Then the LREAB...

USRES AMC incompetence 20

AMC Incompetence in Appraisal Management

I’m told USRES routinely sends orders to out of state appraisers for orders in areas they don’t work in. Is this indicative of the Home Point Financial “We care” motto? ATTN: Executive Leadership Gentlemen, see attached copy of an Alabama appraisal order placed by your AMC, USRES. Among our many other efforts on behalf of appraisers and promoting appraisal quality, we periodically communicate directly with lenders that use AMCs. We do this to make sure they are aware of any substandard practices or services that may be offered in their name. This particular issue is not an isolated instance. Though...

Bifurcated Appraisal Fans Can Claim SOW Till They're Blue in the Face 50

Hybrids vs USPAP Scope of Work Rule

Supporters of the bifurcated appraisal can claim scope of work till they are blue in the face… Appraisal Buzz published an article written by Joshua Walit on July 31, 2019 titled Nothing New Under the Sun: The Varied Face of Appraisal. The article brings up some good points, however; it does not take into account the reality of the market and the control of the lenders and appraisal management companies in the process. The mere fact that the appraiser does not have control over the person completing the inspection and in most cases, no way to even know who is providing the...

No Shortage Exists - Bankers Data Proves No Appraisal Shortage Exists 9

No Shortage Exists

No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. https://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Score Card, Turn Times, Undue Pressure & Appraisal Independence 16

Appraisal Independence

Most appraisers could care less about an amc score card… Professionals don’t treat other professionals like they are in grade school… What exactly is appraisal independence? Dodd Frank requires appraisal independence and associates it with pressure against the value of the property. But what about other areas of the appraisal process in which appraisers receive pressure? Let’s take turn times for example. Normal turn times in a steady market average 5-7 business days in most markets. Market activity, location, complexity, etc. will require longer turn times. First let’s define a business day. This is Monday through Friday and excludes Federal...

Protecting Appraisers Against Frivolous & Retaliatory 3rd Party Lawsuits 6

Frivolous & Retaliatory 3rd Party Lawsuits

Appraisers are routinely coerced & intimidated by third parties to violate their independence and integrity… Honorable Committee Members: We are writing to add our voice to that of the Massachusetts Board of Real Estate Appraisers (MBREA is a State Coalition of professional real estate appraisers) in support of each of the above bills. The American Guild of Appraisers is a Guild within the Office Professional Employees International Union (OPEIU) of the AFL-CIO, representing the appraisal and real estate related financial consumer / taxpayer interests of over twelve and a half million AFL-CIO Family Union & Guild Members; their families, retirees...

Loan Officer' Letter Instructing Borrower to Push Appraiser for Value 38

A Little Push Can’t Hurt Right? Wrong!!

…forget the risky position foisted on the consumer by the loan officer… Well, here we go again. In my previous blog posts titled “Round and Round” and “Pressure My Story”, I spoke to examples of how lenders and/or AMCs have been pushing and pressuring appraisers to hit certain values on transactions. If an appraiser did not hit these numbers, or make changes to make the transaction work in the lender’s favor, the appraiser would be threatened with non-payment, removal from appraiser panels, and/or blacklisted. If you haven’t read those blog posts, feel free to go back and have a look....

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