Stop S.2155 in the Senate
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022
- Is Georgia Going Rogue? - June 13, 2022
- Bias in Automated Valuation Models - February 28, 2022
Call to action to oppose Senate Bill 2155, also opposed by an overwhelming majority of Americans…
We are placing an immediate nationwide call to action to oppose Senate Bill 2155 currently in the United States Senate.
Senate Bill 2155 has a provision, (sec 103) which allows a bank to waive an appraisal in rural communities. This will be detrimental for homeowners and communities in rural areas. A loss of income will also occur for appraisers who cover rural counties.
To see the text of S.2155, click here.
The Independent Community Bank Association has been hard at work promoting this bill. To see what they have been sending to the legislators, click here.
This bill has bipartisan support of 25 cosponsors and we need everyone to contact their representatives and express your concerns with sec 103. We need to take action quickly as this bill will be discussed and voted on within the week.
It does appear we have consumers on our side. The AFR (Americans for Financial Reform) conducted a poll and an overwhelming majority of Americans oppose Senate Bill 2155 and rolling back Dodd-Frank. See the poll results here or posted below.
This does not mean that Congress will listen, so we need to be vocal NOW!
A sample letter to use as a guide has been written by Lori Noble. See the sample letter here or below.
To find your Legislator, click here.
Sample letter by Lori Noble
The Honorable (Name)
Washington, DC 20510
RE: S.2155, Section 103, False Claims of Appraiser Shortage
Dear Senator (Name),
I am writing today about the Economic Growth, Regulatory Relief, and Consumer Protection Act, referenced as S.2155. As a Certified Appraiser in (STATE), I am concerned about Section 103 and specifically the exemption of appraisals for real estate located in rural and underserved areas. There are a few points we would like to share as a professional valuation provider in our rural regions.
Mortgage lenders are trying to convince lawmakers there is a shortage of real estate appraisers in our country, specifically in designated rural markets and this simply is not true. There has always been a limited number of appraisers in remote regions but area appraisers respectively serve those sectors of the market place. Section 103 would allow banks to blanket more than (% coverage) percent of the state. To claim there are no appraisers in that much territory is simply false.
The problem is, the passage of the Dodd-Frank Act caused a proliferation of Appraisal Management Companies (AMC’s), although not required by law. It is noted publicly that AMCs control more than 80 percent of mortgage market appraisals in the United States. The perceived intent was for them to act as intermediary between lenders and appraisers to eliminate coercion, protect consumers, and provide fully independent appraisals to clients. The opposite effect has happened and it is harming consumers with excessive fees, causing inferior quality appraisals, and fake claims of an appraiser shortage. Lenders and third-party AMC affiliates caused the market push back because of poor business practices and not investing in the cost of doing business in rural regions. To offset the negative economic factors affecting appraisers who will not work for 50 percent the market rate (which lender/AMCs call reasonable), they have created a false appraiser shortage narrative that seriously harms the safety and soundness of housing markets and the public.
I appreciate that community banks and credit unions want to be involved in appraisals, but am concerned about the possible gaming of the system as proposed. Without clarification, one can imagine the scenario where a bank would contact three out of area appraisers, offer them a low fee to be declined, and move forward with no neutrality to their internal valuation processes.
Section 103 defies the logic, intent, and the spirit of FIRREA for which it was written. Further investigation is recommended for transparency, real facts about allegations of a fake appraiser shortage, and where fees paid by consumers to third party lender affiliates for appraisals is going. I assure you, not all is going to appraisers and there is not accountability for the difference.
Thank you for your consideration. Appraisers are more than willing to serve our community bank and credit union customers across the country. Please contact me at (phone number) to discuss further as I am available to answer any questions you may have regarding this very sensitive housing economy matter.