Tagged: AMCs

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 24

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

Need for Speed? AMC vs Direct Lender Ordered Appraisals TATs Study 104

Need for Speed? Hybrids are NOT the Answer!

…surveys indicate that appraisals ordered directly by lenders take much less time… Dear Colleagues, There is a current narrative that appraisals take too long and cost the consumer too much! Does this sound accurate? Preliminary coalition surveys indicate that appraisals ordered directly by lenders take much less time than appraisals ordered by AMCs. Additionally, the cost of Hybrid Appraisals has been disclosed in reports as $495 being paid to the AMC. How is this a savings to the consumer? They get an inferior valuation product and pay the same price as a full appraisal. Who is truly benefiting from this scenario? Fannie...

States Back LREAB Against FTC - FNMA Ends 1004MC - Stress Test Failed? 5

States Back LREAB Against FTC

States Support Louisiana Real Estate Appraiser Board against the FTC States (and appraisers) are very interested in the outcome of the LREAB vs FTC to protect their own sovereign actions. On July 11, 2018, the states of Mississippi, Idaho, Iowa, Rhode Island, and Utah filed an amicus brief with the United States Court of Appeals for the Fifth Circuit supporting the Louisiana Real Estate Appraiser Board. See the entire brief here or below. The outcome of this will impact each and every one of us. As we reported a few days ago, one lender, BB&T, has opted to step up...

Financial Ecosystem Changes & ASA's Response to the Treasury Report 10

Financial Ecosystem Changes

Treasury report calling for a more digitalized mortgage process, including the use of AVMs, hybrid appraisals & appraisal waivers… A few days ago, HousingWire reported the Trump Administration calling for sweeping changes to the financial ecosystem. In short, the article references a report by the Department of the Treasury calling for a more digitalized mortgage process, including the use of AVMs, hybrid appraisals and appraisal waivers. The HousingWire article has a link to the Treasury Report, which is 222 pages or you can click here to read the report. VaCAP has received a copy of the ASA’s response to the Treasury Report....

Push for Automated Appraisals... Even Paranoid You Can Have Enemies 16

Just Because You’re Paranoid Doesn’t Mean They Aren’t After You

It appears the government sees the future of appraising as one driven largely by Automated Valuation Models, Hybrids, and outright appraisal waivers…. The title for this article comes from a famous quote by Joseph Heller (the author of Catch-22 fame). I thought of his pithy quote when reading the recommendations by the Department of Treasury to the president. The title of the report: “A Financial System That Creates Economic Opportunities Nonbank Financials, Fintech, and Innovation” seems innocuous enough. However, some decidedly non-innocuous observations / recommendations regarding the appraisal industry appear starting on page 103. The report starts off promising enough;...

Appraisal Taking Too Long False Narrative - Contract Date vs Acceptance Date 4

Appraisal Delays Study

Contract Date / Acceptance Date Study expanded. VaCAP did a sample study this past winter to determine the number of days from contact ratification to appraiser acceptance from both amcs and lenders. The results were a 9 day difference with amc’s taking 18 days and lenders only 9 days to assign the appraisal. We have just asked our sister coalitions to complete this survey as well. for a larger data pool and are asking every appraiser to once again participate to help our industry. This information will be used to counter the narrative the appraisal is taking too long. Below...

A Rebuttal to Real Estate Agent's Article Slamming the Appraisal Industry 46

Slamming the Appraisal Industry

A Rebuttal to Real Estate Agent Slamming the Appraisal Industry… Forbes recently published an opinion article that attacked the appraisal industry and placed all the blame on appraisers for real estate transactions falling through due to a “low” opinion of value. The article was written by a real estate agent out of Arizona. While he raises some good points, he is conflating a lot of issues together. 1) He does point out that there are bad appraisals. We all know that. There are bad appraisers just like there are bad agents who have clients list a property far above any...

MISMO Blueprint... The Evil Octopus - AppraisersBlogs 5

The Evil Octopus

Appraisers, it’s not paranoia when ‘the bastards’ really are out to get you (end us as a profession). …Find each octopus and how they relate to our jobs. Look at MISMO Directors list… An Open Letter to Appraisers: Residential & Commercial This started as a response to a blog post by a respected appraiser concerning the influence of AMCs. During drafting it was clear that trying to explain AMCs was only part of the bigger struggles we face today. Picture a violent “all in” three-way gang fight among Octopi. Say a dozen on each side. That’s 36 Octopi x 8 tentacles...

CAP in DC: Information in Hybrids & Liability, Past Due Invoices, HBU... 4

100% Liability for Information Relied Upon

…courts have ruled if the information is included in the report and relied upon, the appraiser is responsible for the information… Last week representatives from VaCAP attended The Appraisal Foundation Advisory Committee (TAFAC) and Industry Advisory Council (IAC) joint meeting. We promised a recap of the events, however, both The Appraisal Foundation and Jonathan Miller have already released a summary and did an outstanding job. To read about the event, simply follow this link. The one thing every appraiser needs to understand about the new hybrid product is their liability; specifically the appraisers has 100% liability for the report and the information...

Liability Risks of Hybrids to Appraisers and Others 12

Liability Risks of Hybrid Appraisals

“Hybrid Appraisals” – Speaking about the Liability Risks to Appraisers and Others at The Appraisal Foundation’s Joint Council Meeting “Hybrid appraisal” liability? I am looking forward to speaking about the subject at a joint meeting of The Appraisal Foundation’s two advisory councils — The Appraisal Foundation Advisory Council (composed of 60 non-profits and government agencies) and the Industry Advisory Council (composed of 35 business entities with interests in valuation). “Hybrid appraisals” (which provide a desktop value opinion from a licensed/certified appraiser relying on a physical inspection of the property by a third party) are being marketed by AMCs and technology companies...

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