Might have been a non QM loan-not FRMC, non FNMA, etc. Anyway, something stinks worse than an abandoned fish market.

Accountability. Who needs it?

If you are a Realtor, I should remind you of your ethics which you just violated on a public forum. I have not (yet) wasted my valuable time to look you up. But anyone can, and report if warranted. If you are not a Realtor, or even if you are, clearly you are lacking knowledge of how appraising works.

LMAO.

Goes to show she’s GOT to be a big gov’t employee, failing upward.

Don’t you think that’s a little tough? After all her two sentence response had no spelling errors and was grammatically correct. She sounds like she migt be a Rhodes Scholar. The in-depth analysis she provides is simply stunning as well as the research performed in classifying most appraisers. We should all be humbled by her actually wanting to share her vast knowledge and expertise with “idiot” hayseed appraisers. Hey, she even knows the meaning of the word syntax….impressive.

Oh bummer, lost again. I’m just glad that somewhere, people are still reading.

Niall, what else did you take away from that post besides various free writing grammatical errors?

^Looks like we found another HUD/AMC minion.

Naill, judging appraisers or the appraisal industry by a single post on a message board is narrow minded and infantile. Pointing out grammatical errors is poor form-this is the internet and not advanced literature.

But good luck with your HUD layoffs, or whatever…

Niall A. Joyce
Chicago

Yes but what can I do? The unregulated junk fee proponents are all over linked in, reddit/appraisal, af, and quasi official looking faux news like housing wire and beyond, buying article space and posting positive pr spin half truth corporate funded ‘news’. They have been doing this for some time. Billions of dollars worth of unchecked consumer fee raking over more than two decades buys a lot of influence.

Individual state regulatory boards or individually licensed appraisers are unable to do anything to correct these imbalanced structures, when set against a corporate scale. When a state appraisal oversight board of a half dozen to a dozen volunteers and special appointees go against amc corporations, worth at times hundreds of millions of dollars, their parent international lender organizations, special interest groups and legal staff. With a member of the amc world sitting on that board. This regulatory structure is dysfunctional. The state based regulatory system was designed to manage individual transgressions from individual licensees and is wholly inadequate to deal with matters of corporate licensing and corporate scale business oversight (amc’s and other automated and outsourced process which bypasses the use of individual licensees.)

Amc’s are supposed to be overseen by the ASC. The ASC and ASB are supposed to provide effective administration and oversight of the licensing system and it’s structure for both amc’s and appraisers. They know there is a problem with amc’s yet choose not to alter or expand the oversight system, constantly citing cost savings and ease of business operation as primary decision making factors, which has been the status quo line for why to replace important appraisal safeguards from GSE’s for some time now. ‘Stakeholder input.’

Every single dollar the ASC handles, TAF, and ASB, are all ‘federally appropriated dollars’. Because they are congressionally chartered, provide grants and other benefits, the moment any dollar from any source falls under their handling and purview, that becomes a federally appropriated dollar. Meaning many federal rules responsibilities and restrictions are applicable to the organization and it’s fellows when they use or spend those dollars. The notion their money does not come from federal or congressional appropriations being that they are ‘self funded’ has been the excuse to skirt many an applicable federal regulation for some time.

The OCC office of the Comptroller is supposed to oversee the ASB to assure the program is being managed and ran with proper oversight and compliance, is maintaining effective oversight in alignment with the congressional charter, the reason the programs were formed in the first place. The OCC is tasked with a yearly or ever so often review and reporting of the ASB’s program and downstream accompanying related institution’s compliance (taf & asb). They’re all rubber stamping everything and nobody is acknowledging the problem with inadequate amc oversight, the amc industry having skirted other rules by engaging in far more than ‘appraisal management’, effectively circumventing and avoiding a multitude of regulations which the entire structure of the regulatory oversight system was built around; overseeing individually licensed mortgage brokers, individually licensed realtors, and individually licensed appraisers.

Yet whenever any problem with the lenders or mortgage companies rolls around, mysteriously everything is kicked down to appraisal oversight boards via the amc tie in. Stomp down the appraiser, levy inadequate fines, providing effective liability and accountability shielding for the corporations, mb’s, and realty agents. Many warned this would be the end result of amc’s sitting on state boards, amc’s not having individual licensing requirements for all staff whom deal with appraisers to be required to have appraisal licenses themselves. Improper co mingled fees, and the scale of representative comparison, lack of more appropriately balanced individual accountability. The david vs goliath argument. Conflicts of interest at scale.

The primary system correction which never came to be was the DF Reg Z C&R rule which would have fined amc’s $10k/$20k daily recurring fines for each and every instance of not paying fair market appraisal fees as discovered through fair market fee surveys which did not include amc data. Thereby compelling the lenders to adhere to the traditional structure of individually licensed mb’s dealing with individually licensed appraisers, even if the ‘separation from loan production’ rule was still in place. Otherwise the amc’s would have been cost prohibitive for lenders to utilize. Lack of C&R means the appraisers shoulder the lenders costs while amc’s primary focus becomes paying appraisers less, charging consumers more, and outsourcing everything possible to non appraisers.

Nobody really knows or can see the scale of consumer harm under these systems. However the fact that three out of four licensed appraisers refuse to work with amc’s is a glaring admission from this industries own ethical experts why there is such a problem. Lying on forms, cheating, stealing, junk fee raking, violating appraiser independence, restriction of trade, racketeering, dumping bad loans on home owners, protecting the lenders interests primarily, redirecting working opportunity for appraisers away to non appraisers instead. Just another day in the amc industry.

The appraisal industry and consumers whom benefit from our protective presence does not need me or any other individual person. Everyone needs better education on how the regulatory oversight structure is supposed to function, to more clearly articulate how effective corrections can be implemented. Things were so much simpler and straight forward when licensed appraisers simply dealt with licensed mortgage brokers directly, no amc necessary and often prohibited from being involved. I’ve drawn up a special meme to provide a simple visual illustration.

State boards appear incapable of providing oversight against corporations when hardly anyone in those corporations is required to have individual licenses. None of the three state based oversight branches (realty, mortgage broker, or appraiser) appear to properly coordinate or communicate with each other in any individual US state. The ASB has failed in their prescribed duty of effective oversight, for their inability to reign in the exploitative amc model. OCC has rubber stamped approved the ASB process without proper oversight or attention to the details year after year. FHFA ties in, being the federal entity tasked with GSE conservator oversight. FHFA conditioned GSE executive compensation on their quarter after quarter ability to drive full service human appraisers out of the GSE consumer protection process for many years, promoted the avm final rule which incorporates DEI policies, aka disparate valuation outcome adjustments via automated avm algorithms lenders are required to use in leu of appraisers, associated expansion of appraisal waiver allowances.

HUD also had unique problems which are more commonly understood and sensationalized, yet not actually the heart of the problem. Those without detailed knowledge of the systems dysfunctions are led to believe a fictitious notion of ‘appraiser bias.’ When what they are really observing is yet another manifestation of institutionalized predatory lending activity over the long term. All around failure to protect the public from predatory lending and financial systems instability through multiple regulatory institutions, purposeful dismantling of over 40,000 appraisers small businesses who’s income revolved primarily around full service GSE lending work. Runaway housing pricing is but one result. Amc’s now function to facilitate the behaviors they were put in place to prohibit, having become ‘industry stake holders’ themselves on a corporate scale. ‘Appraisal modernization!’

Oh I see. The bill only protects appraisers whom are not in service to the American public dealing with GSE lending, non gse lending, or any incorporated type service. Nor does it protect against false claims of racism. Brilliant. What’s the point? Colorado genius legislators are at it again. This time with bi partisan backing!

I worked 30 years as an independent fee appraiser in Chicago. I retired and now live in Europe.

Spot on Baggins. It can be twisted and theorized any way one wants but, at the end of the day, it is still the obvious. Facts are facts
Unsupported enuendo are not facts and used in an attempt to obscure the obvious. This of course is predicated on the reporting being accurate.

Who do you work for The GSEs or an AMC?

While this is a logical solution it’s not practical. There is a reason the AMC’s continue to get away with this. Self-centered, “I’m in it for me” decenters in the appraiser ranks. They don’t or can’t process the fact their willingness to play the game is simply contributing to a quicker demise of the very source of their income for the quick dollar; akin to cutting their own throat. It is an appraiser problem as much as an AMC problem.

YOU NEED TO CALL OUT THE AMC.

Appraisers need to know which AMCs to stay away from, if you do AMC work.
The only way any of this gets better is to starve the beast.

Several years ago I performed a review on an appraisal I found all 3 of his sales comps did not even exist. I delivered me review report to my client. I looked at my States Appraisal Board to see what the penalties were for the original appraiser. I have never seen the fraudsters name in any sort of action for him. I csn only assume the lender never filed a complaint.

Amen. The fine for the so called Realtor should be high enough to get the victim to an at least amount to make her whole. The AMC DEFINITELY needs to be shut down in every State they operate in and also be fined. I agree, we all need to know who the AMC is.

Post links.
I’d like to see what they are saying.

Thank you Baggins! We need your help. at appraisersforum the GSE mouthpieces are spreading all sorts of disinformation about their criminal activity!!