I no longer care about “customary”. “Customary” in Dodd-Frank’s customary and reasonable is a negatively biased fee before state studies begin! We all know that the “C” part of C & R is supposed to represent the normal fee charged by most appraisers for similar work and conditions. Some AMC appraisers even know the “R” part is supposed to be an amount that is reasonable based upon ALL factors necessary for completion of the assignment in a USPAP compliant and professional manner. Unfortunately HVCC and the AMC havoc it wreaked has existed far too long for there to be a...
Appraisers, The Consumer Finance Protection Bureau (CFPB) has mandated new residential mortgage application and disclosure procedures, which take effect Oct. 3, 2015. Here’s a link to a brief article about this. When a consumer applies to a mortgage lender, the lender requests certain information from the consumer before the clock starts ticking in terms of ‘timing requirements’ on the consumer’s application. When the application is considered “complete”, the lender has 3 business days to provide the consumer with the Loan Estimate document. What’s of concern among lenders and appraisers is the speculated inability to change appraisal fees, which is disclosed...
Appraisal Management Companies (AMC) are changing how our profession works. It’s important to know exactly how they are affecting the real estate process, especially if you are a home-owner, looking for real estate or are involved in another part of the property. Who does an Appraiser work for? An appraiser works for “The Client” named in the report who ultimately responsible for the appraiser’s compensation. It is important to realize that while a borrower may have paid a lender or third party the cost of the appraisal, “The client” remains the only party authorized to use the report. The appraiser...
Functional obsolescence is the reason many appraisers are going out of business. On a daily basis, appraisers moan: “It’s because of the HVCC that my business is down” or “that AMC or X or Y or Z caused my income to decline.” Really? Are you sure? So, why is my company buried in business and you’re not? We’ve all heard about blacksmiths being out of work; Seems the use of horses has declined. And the need for typewriter repairmen, the demand just isn’t what it was 20 years ago. The people in these jobs failed to adapt; Maybe appraiser are having the same problem....
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...
I Did Not Quit when HVCC, UAD and CU Came Along. I Do Not Quit, Not Ever! I do not quit. Not ever. I have a different perspective based on lifelong lessons from my father. I did not quit when a lost helmet in the last play of the season made it painful to block during high school football. That effort got me my school letter despite being 3 quarters short. It was worth the headache. I did not quit Boot Camp in 1969 when at 129 pounds and six feet, very few thought I’d make it. To this day I...
Appraiser No More, Think I’ll be a Lawyer: it takes less time to get a law degree than to get an appraisal license. I heard from an old friend today that worked as an appraiser in Raleigh, NC for at least a dozen years. Shortly after 2009 and the HVCC, he (like so many others) started looking for career options. After appraisal reports kept requiring more and more pages, had more and more restrictions (far too many that were totally useless and had nothing to do with the home’s value), and his fees kept going down instead of up, he...
Why I’m Leaving Residential Appraisal – Dear AMC, Goodbye! The Law of Unintended Consequences is a law, like Murphy’s Law, which is always lurking in the background to foil the attempts we humans make to control the world around us. It is particularly true of government attempts to reduce crime. A couple of examples follow: I used to love air travel. I was a flight test engineer at Boeing and for many years I flew all over the world for both work and recreation. Then came the shoe bomber. Now I wait in long “security” lines while thousands of security...
We Studied USCRAP… Not so long ago I had multiple clients. They would call me if they needed my professional services and trusted me to perform a satisfactory service. I’m a streetwalker. I drive and walk the streets looking at houses and photographing them from the street (outcalls) and sometimes going inside to determine condition (in calls). This worked well for many years until the Federal Government got involved in the late 1980s. The Feds discovered that a few streetwalkers had exaggerated their claims of professionalism and service and declared in the 1989 DIARRHEA that all streetwalkers must be licensed...
Place this statement into your canned comments as it can serve you well. I received a copy of Ken Harney’s recent CU article today via email. The article was sent from an old appraiser contact that remembered me from the fight that I was leading to boycott AMCs from 2009 to 2010. Ken Harney is undoubtedly the best friend an appraiser could ever have in the national media as he was the only syndicated columnist willing to cover the injustice of HVCC. He and I exchanged several emails during those days. I found no ground breaking news within his article....
