It has come to my attention that the attached settlement is being proposed to the BR Trustee in the ES Appraisal case and thought that it was important that the information be passed along to whomever might need it since many of our members have been affected. Please forward to whomever you believe might be owed fees in this case. I would recommend that anyone do their own research on this as I am only passing along information that was given to me third hand. It is the belief of others that this agreement will forgo millions of dollars in...
NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...
Lately, there has been some controversy surrounding the announcement of CoesterVMS implementation of a flat fee appraisal structure which went into effect on January 1. The announcement appeared on CoesterVMS Blog on January 7: CoesterVMS, a nationwide appraisal management company, has implemented the appraisal industry’s first ever flat fee model for residential appraisals. Under the flat fee model, which took effect on January 1, 2013, all conventional appraisals for mortgage lenders are priced at $450 while FHA appraisals are $475*. Customarily, appraisal management companies utilize a tiered fee structure, whereby prices are determined based on the property type or the...
The National Association of Independent Housing Professionals (NAIHP) led by Marc Savitt is petitioning the Consumer Financial Protection Bureau and is asking those harmed by the Interim Final Rule on Appraiser Independence to sign and forward the online petition. To Consumer Financial Protection Bureau (CFPB), Richard Cordreay, CFPB Director: Allow NMLS loan originators to order appraisals directly from appraisers Consumers and small business are being significantly harmed by the Interim Final Rule on Appraiser Independence. Consumer costs have increased by over 2.8 Billion dollars a year; thousands of small business residential appraisers have gone out of business, as the rule diverts...
NAIHP: “Congressional Subcommittee REFUSES Small Business Brokers and Appraisers a Seat at the Table” For the second time in a week, the Subcommittee on Insurance, Housing and Community Opportunity, Chaired by Rep. Judy Biggert (R-Illinois), refused small business housing professionals the right to be represented during Congressional testimony. On June 20th, the Subcommittee held a hearing entitled: “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses?” Although, Banks were represented three times on the panel, Brokers were intentionally excluded. NAIHP argued to represent the industry, but was refused because the panel was full. On June 28th,...
An outline exposing the unintended consequences created by HVCC and the Interim Rule February 23, 2012, Hon. Richard Cordray, Director, Consumer Financial Protection Bureau Re: Appraiser Independence Regulations Dear Director Cordray: Thank you for taking the time to meet with NAIHP on January 26, 2012. We always appreciate the opportunity to meet with the CFPB and discuss issues of concern that affect consumers and small business housing professionals. Although, our meeting covered a broad range of issues, my comments today are limited to the ongoing problems associated with “Appraiser Independence.” Today’s interim Rule on Appraiser Independence, was built on the...
