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For the term "clear val".
Increased Regulatory Persecution of Real Estate Appraisers - USPAP 21

Increased Regulatory Persecution of Appraisers

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...

AARO / AGA / AI / American Society of Appraisers / Appraisal / Appraisal Institute

USPAP Confidentiality Questions... Can Using a Contractor Be a Violation? 7

USPAP & Questions on Confidentiality

How can using such a contractor not be a violation? In the context of a real estate appraisal, especially a residential real estate appraisal for a lender thru an AMC, what is confidential? First, look at USPAP’s definition of confidential information (lines 105 – 108 in the 2018-2019 edition). It says “confidential information [is] information that is either…identified by the client as confidential when providing it to an appraiser and that is not available from any other source; or…classified as confidential or private by applicable law or regulation” (ibid; emphasis added). Notice confidentiality flows to the client, not to any...

Appraisal / Appraisal News / Appraisers News / Fannie Mae - Freddie Mac / Uniform Standards of Professional Appraisal Practice / USPAP

12-24 Hour Valuations: How Are We Worth So Little? 13

How Are We Worth So Little?

An appraiser sent me the following email. It has become clear to me that the valuation industry that engages appraisers now places more value on the physical inspection than it does the actual valuation itself. Why? They can’t replicate the interior inspection so the valuation portion is where the fee shaving occurs and believe they can come up with the value themselves or find people that will work for wages that won’t attract people who are competent, but rather, people that are desperate. [Bold for emphasis] Hello, You are receiving this email because you have expressed interest in completing desktop...

Snippets

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response 109

Expert Wants to “Eliminate” Appraisers

Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with an industry expert who openly stated she wants to “eliminate” the appraisal profession. No subtlety, no nuance — she wants us gone! Given the name of the website, I didn’t expect to find too many pro-appraiser viewpoints. I ran a search for the term “appraiser” on the website’s internal search engine and many of the articles that came up were about eliminating the profession or the current state of appraisal waivers.…to “eliminate” the appraisal profession…   Rather than read the article...

AMC / American Society of Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News

Proof of Title - The Edification of Uninformed FHA Bureaucrats 5

Proof of Title

…you have only cleared title to the proposed collateral property back to 1803… Rebuilding New Orleans after Katrina often caused residents to be challenged to prove home titles back hundreds of years. That is because of community history stretching back over two centuries during which houses were passed along through generations of family, sometimes making it quite difficult to establish a paper trail of ownership. A New Orleans lawyer sought a FHA rebuilding loan for a client. He was told the loan would be granted upon submission of satisfactory proof of ownership of the parcel of property as it was...

Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / Federal Housing Administration / FHA

What Does it Mean Support and Prove? Uncertainty Is Risk 2

What Does it Mean ‘Support & Prove’?

What we do is subject to uncertainty. I searched the words: support and prove in both USPAP and in The Appraisal of Real Estate”. Interestingly, the word prove is not found in either document in this context. The fuzzier word support is found throughout both. The word ‘support’ seems to support supporting your opinion. How is the word “support” used in the context of making adjustments? I decided the dictionary would provide some support for how the word ‘support’ is used. The results are curious, perhaps troubling. Which comes first: the opinion, or the analysis? Do you support your opinion, or do you come to a result from doing your analysis? As a verb, the meanings of ‘support’ include: suggest the truth...

Appraisal / Appraisal News / Appraisers News / Uniform Standards of Professional Appraisal Practice / USPAP

Hybrid Committee Meeting Recap 25

Hybrid Committee Meeting Recap

The Recap The VREAB Committee meeting on hybrid appraisals met last week. The turnout was a decent one. Some traveled a great distance to attend. There were appraisers, assessors, consumers and trade group representatives in attendance. The meeting started with the Appraisal Foundation Video on Hybrid Appraisals. Public comments followed and many spoke and shared their concerns. Examples of hybrid appraisal products were submitted to the committee. Protecting the public was a key discussion and the following existing Virginia laws and regulations were discussed. 54.1-2009 Definition of appraisal- “Appraisal” means an analysis, opinion, or conclusion relating to the nature, quality,...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

The Erosion of Bank Underwriting Standards. Let's Get Rid of Appraisers. 18

Let’s Get Rid of Appraisers. What Could Go Wrong?

Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened. It Is Now Time To Listen Again as History is About to Repeat Itself. There’s a proposal from the FDIC, Federal Reserve, and Treasury Department not to require appraisals for some mortgages under $400,000. The Trump Administration wants to disrupt the role of appraisers, but that’s not a good idea. This change can impact several groups in particular: 1) Consumers: Removing appraisers from transactions can mean a lot of loans get made that shouldn’t be made. Does that sound familiar? We...

Appraisal / Appraisal News / Appraisers News / Automated Valuation Models / AVM / Fannie Mae - Freddie Mac

Open Letter to Taxpayers... Afterall, Taxpayers Aren’t Stupid 32

Open Letter to Taxpayers

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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