I found this interesting ’40 facts you should know about trid’ article.
http://www.datafacts.com/lendingsolutionsblog/40-trid-facts-you-need-to-know

Points #8 & #15 caught my eye for appraisal process.

While point #23 seems to be the wink towards considering 15 year notes, but falls a little short if there is no standard comparison of figures. I think all 30 year applicants should also be presented with an alternative 15 year disclosure so they can compare cash equivalency. However they compare that, over brief term, long term, expressed as dollars or portions. The most meaningful expression of that to me as a consumer, is the total cash equivalent difference for total dollars out of pocket 30 vs 15 with the rates at the time. I read a news story yesterday the current presidential administration may take a step to wind down the gse’s. One could dare to dream that risk could be properly allocated one day in the future, and the appraisal might be meaningful again as a vital tool to measure risk, not just a speedbump along the way to subsidized insurance.

That’s not true. IF it were true, then the “change in circumstances” is that the appraiser refuses to work for fees he or she never had a hand in negotiating, and which are far below the fee level considered to be ‘reasonable; for the amount of work required to properly complete the assignment.

Where is the FTC again? Oh! In Louisiana interfering with free trade again, and enforcement of federal regs designed to promote free trade..

Mike, thank you for that simple direction. I will tell them in the future to simply get a new trid disclosure filed. Previously I had told them not my problem, just take a little loss I guess. This is what appraisers are up against if they choose to drive their own fees.

I searched email because I knew they’d used that excuse before, here are 2 brief exerpts.

Thank you for your email. I understand your frustration./ Unfortunately this client is TRID, and we cannot not adjust fees unless it is CIC. I thank you for your time, and wish you the best of luck.

And another one:
By virtue of our role we’re placed in a position between the appraiser and the lender (and consumer) and are often challenged with crafting solutions to satisfy all sides while meeting the compliance demands of today. Between TRID and the larger-than-one-might-imagine scale of making price changes in our clients’ systems (and with their staff) we suffered losses in the state of XX. Obviously these losses aren’t material to the company’s financial health, but we chose to do that as a service to our valued clients. As our appraiser, I can guarantee you we will pay your C&R fees in XX, which lately seems to change quite often. It sure is an interesting time there.

It’s doubtful the commissioners that directed the case to be filed awoke one day and said “Gee, I wonder what Louisiana is up to these days with respect to Dodd-Frank Act C&R fee enforcement? Let’s go check.”

Let’s see the original complaint that was filed that created this. FOIA guys!

Aside from that, I want to see FTC investigate ALL banks that have service level agreements (SLAs) with AMCS wherein appraisal fees that ultimately appear on the TRID (HUD1 replacement) are set before a mortgage request is even originated by a consumer.

When a loan application is taken, the loan officer quotes the appraisal fee based on the SLA-not based on a specific property or the complexity of appraising it.

If it turns out (30% to 40% of the time) the assignment is much more complex than anticipated, there is no effective provision for negotiating a higher fee commensurate with the added work. Nominal $25 fee increases on top of fees that are already 20% to %50 low is not ‘negotiating’. AMCs and lenders including NCUA regulated credit unions all claim TRID does not allow them to go back to the borrower and ask for higher fees. Of course, they are flat out lying. They ARE allowed to go back…they just need to have a new disclosure signed.

THAT IS PRICE FIXING!

This reminds me of the burglar who sued the store because he was shot while attempting to rob the store.

And, you have not the slightest. God Bless 🙂

I will remove myself from this FB Blog, Appraiser Blog Website and any further communication to Appraiser Blogs in general. I provided a reasonable question. I appreciate your past cooperation. God Bless You 🙂

Seems like a double standard to me !

Benjamin, based on your comments, it appears that you have some unresolved issue with LREAB. Whatever the case may be, this is not the place to settle your issue with your board. We recommend you get in touch with them and discuss your matter privately. We appreciate your cooperation!

Benjamin, I don’t know who you are and honestly do not care. If you are an appraiser or even a trainee, for you to make such a comment shows a complete disconnect with this profession and I would encourage you to find another means to support yourself. Appraisers require deep thought and analysis to be successful. I am not a resident of Louisiana, nor am I licensed in Louisiana, but they have my full support in defending this action. Louisiana is a  pioneer in the industry and has set the stage for other states to follow. They are not flakey as you state. They are professionals that understand the industry, the law, and their role in protecting consumers. From your comments on appraisersblogs, not sure many could say that about you.

This case against Louisiana is a game changer for appraisers. If the FTC prevails in this case, any chance of a decent living in this industry is greatly diminished. If Louisiana prevails, we can begin to move forward and regain our profession back.

Flakeeeyyyyyy 🙂