Category: FHFA

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The Network Letter RE CU Program

Network of State Appraisal Orgainzation’s letter to FHFA Director Watt Regarding Fannie Mae Collateral Underwriter (CU) Program For over the past couple of months, VaCAP has participated with 18 other State Appraiser Coalitions in drafting an unified response to Fannie Mae’s Collateral Underwriter Program. Their letter to FHFA Director Watt briefly outlines their concerns, offers recommended solutions, as well as asking for a meeting to discuss the issue for the benefit of all vested parties. Please take a few minutes to peruse the letter below: Dear Director Watt: On behalf of the independent state professional appraiser organizations signing below, I...

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HVCC Impact on Appraisal

Impact of the Home Valuation Code of Conduct on Appraisal and Mortgage Outcomes During the housing crisis, it came to be recognized that inflated home mortgage appraisals were widespread during the subprime boom. The New York State Attorney General’s office investigated this issue with respect to one particular lender and Fannie Mae and Freddie Mac. The investigation resulted in an agreement between the Attorney General’s office, the government-sponsored enterprises (GSEs), and the Federal Housing Finance Agency (the GSEs’ federal regulator) in 2008, in which the GSEs agreed to adopt the Home Valuation Code of Conduct (HVCC). Using unique data sets...

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

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...

PADS - Appraisers Running for Exits 8

PADS – Appraisers Running for Exits

We urge appraisers to review the PADS Model Current economic trends suggest your appraisal practice will not survive beyond 2015. Appraisers are running for the exits, with many moving into Ad Valorem, and some into cost estimating.  Client accounts you thought were safe have been converted to ether and dispersed among a dark refinancing void. You’ve gone from completing six appraisals per week to camping by your email, in hopes of an AMC broadcast assignment appearing. Where you once had time to think about accepting the assignment, you now have less than 2 seconds to accept, because like you, ninety...

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Minimum Requirements for AMCs

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...

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Fannie Mae’s Appraiser “Blacklist”

Fannie Mae’s new “Appraiser Quality Monitoring” initiative that creates an appraiser “do not use list” or “blacklist” has alarmed many working appraisers, especially since at least a portion of the process is automated. Placing an appraiser on a Fannie Mae exclusionary list would effectively end a career, therefore, it is critical that appraisers…

Small Towns and Rural Areas Appraisal Requirements 3

Rural Areas & Small Towns Appraisal Requirements

A common misconception of Fannie Mae’s Appraiser Independence Requirements (AIR) is that lenders are required to use third-party vendors or appraisal management companies (AMCs) to ensure compliance. In fact, lenders are not required to use an AMC or any other third-party vendor to order appraisals…

Proposed Rule for AMCs 0

Proposed Rule for AMCs

Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...

USPAP violations 1

FHFA: Fannie, Freddie Fail to Analyze Appraisal Data

Increasing FHFA oversight of UCDP use… Fannie Mae and Freddie Mac failed to fully analyze data from the Uniform Collateral Data Portal and continue to take unnecessary risks when purchasing and guaranteeing single-family residential mortgages, according to a report from the Federal Housing Finance Agency’s Office of the Inspector General, Mortgage Daily reported Feb. 6. The report indicated that the two government-sponsored enterprises are not taking full advantage of appraisal data collected through the UCDP that the Federal Housing Finance Agency directed the GSEs to use in 2010 in an effort to improve loan quality and risk management. Mortgage Daily...

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“Fake” Appraiser E&O Insurance and Shady Things from AMCs Too

Outright Fake E&O For many appraisers and also some AMCs (appraisal management companies), the only reason they purchase professional liability insurance (E&O) is because a client requires them to show coverage in order to receive work.  The fact that some appraisers and AMCs only look at insurance as an “E&O ticket” leads to some unfortunate examples of fraud, which appraisers, firms, AMCs and clients should be aware of. Before I get to the fakery, however, I’ll explain that our purpose in providing E&O, and also the reason that most of our insureds purchase it, is because E&O first serves the insured by providing...

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