American Society of Farm Managers and Rural Appraisers - Appraisers Blogs

The Great Debate on Appraisal Fees

Isaac Peck — Mon, 28 Oct 2024 12:30:09 +0000

She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee paid by the borrower, which prompted her to stop working with AMCs because of the lack of transparency. The appraisal industry is abuzz with a discussion about appraisal fees. The Consumer Financial Protection Bureau (CFPB) recently issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions [Docket No. CFPB-2024-0021] in which it solicited feedback from the public and industry stakeholders on the fees charged to consumers by mortgage providers and related settlement services. The CFPB framed it as...

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Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

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COVID-19 Temporary Appraisal Guidelines

VaCAP Board — Sun, 29 Mar 2020 12:30:03 +0000

Fannie and Freddie are giving preference to desktop appraisals over exterior appraisals, which quite frankly, is completely backwards from what most appraisers believe to be a more reliable appraisal. HUD and the Veterans Administration, on the other hand prefer exterior appraisals…

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Feds Deny Public Hearing

VaCAP Board — Mon, 25 Feb 2019 13:30:13 +0000

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...

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Standing With Us Protecting Consumers!

VaCAP Board — Fri, 15 Feb 2019 13:30:57 +0000

…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...

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Raising Appraisal Threshold Levels

AppraisersBlogs — Thu, 17 Dec 2015 13:30:45 +0000

Adjusting appraisal threshold levels On December 2, 2015, Dave Towne called attention to an article on a potential increase in appraisal threshold levels, which appeared in the ABA Banking Journal. Excerpt: The banking agencies are revisiting the dollar thresholds for their appraisal requirements, FDIC Chairman Martin Gruenberg said in Arlington, Va., today at the final outreach meeting for the decennial Economic Growth and Regulatory Paperwork Reduction Act review. “Based largely on comments we have received during these outreach sessions, we have formed an define working group to review the appropriateness of dollar thresholds for transactions requiring appraisals and other requirements...

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A Wakeup Call for the Valuation Industry: Is Anybody Listening?

AppraisersBlogs — Tue, 16 Apr 2013 12:30:45 +0000

On February 13, 2013 the National Association of Home Builders (NAHB) published a fascinating critique on the world of valuation. The document: “A Comprehensive Blueprint for Residential Appraisal Reform” should be read by every appraiser, every user and every client. NAHB is telling us our core systems are not working and to take another look at our process and procedures. Our systems are too inconsistent, too cumbersome, and NAHB is asking us to improve our efficiency which impacts their and our profitability. NAHB is asking the industry to provide them a uniform, consistent, quality product utilizing well trained staff. These exact...

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AI Advocates for Issue-Specific Appraiser Complaint Forms

AppraisersBlogs — Tue, 19 Mar 2013 12:30:36 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 28 to the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Comptroller of the Currency expressing concern about the broad reach of a proposed Interagency Appraisal Complaint form. The agencies intend to provide a copy of the form to individual complainants, who, in turn, will return to the agency for information gathering and potential referral. In its letter, AI and ASFMRA expressed concern that the proposed form may not be the most effective approach and instead recommended complaint forms...

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Appraisal Hotline Operations Details

AppraisersBlogs — Thu, 21 Feb 2013 13:30:15 +0000

Appraisal Institute Wants Details on Appraisal Hotline Operations The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 12 to the Appraisal Subcommittee asking that it make its proposed protocol for operating the “appraisal hotline” available for public comment prior to its March 29 implementation. In the letter, AI and ASFMRA said that while the concept of a hotline is sound, there exists almost no understanding among state appraiser regulatory officials, practicing appraisers and real estate and mortgage professionals as to how the hotline would function or even of its intended purpose....

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To Disclose or Not to Disclose AMC Fees

AppraisersBlogs — Thu, 25 Oct 2012 12:30:03 +0000

To Disclose or not to Disclose AMC Fees… With the Consumer Financial Protection Bureau (“CFPB”) up and running, there are numerous regulatory issues still pending relating to the Dodd-Frank Act. The regulatory issues include appraisal independence rules, AMC fee disclosure, AMC registration, required physical property visit by appraisers in “higher risk” mortgages, HUD-1/RESPA Consumer Disclosure, and asset backed securities. Of particular note, the CFPB has proposed a new Consumer Disclosure form that is intended to replace the HUD-1 settlement statement. The proposed rule which was release for public until November, allows disclosure of appraisal management company fees, but does not...

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AI Asks HUD to Withdraw Section 8 Provision Eliminating Appraisals

AppraisersBlogs — Fri, 03 Aug 2012 13:48:51 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers issued a comment letter July 16 in response to the U.S. Department of Housing and Urban Development’s proposed rule on regulatory changes to their Section 8 Voucher Program. The rule proposes to eliminate an existing requirement that an appraisal be used to determine initial rent contracts to a Section 8 building owner. HUD cited a “lack of availability of state-certified appraisers” and “increased expenses in order to acquire state-certified appraisers” as the reasons for eliminating the appraisal requirement. In their joint letter, AI and ASFMRA asked HUD...

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AI Continues to Support Separation of Fees

AppraisersBlogs — Fri, 29 Jun 2012 12:00:10 +0000

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers reiterated their support of separating appraisal and appraisal management company fees on mortgage disclosure forms June 20 in Congressional testimony. The organizations originally voiced support when drafts of the Consumer Financial Protection Bureau’s proposed Consumer Disclosure Form were released in February. AI and ASFMRA again expressed their support in written testimony on “Mortgage Disclosures: How Do We Cut Red Tape for Consumers and Small Businesses” before the House Committee on Financial Services’ Subcommittee on Insurance, Housing and Community Opportunity. The organizations expressed support of clear disclosure of...

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Sentencing Guidelines Proposal

AppraisersBlogs — Thu, 15 Mar 2012 12:00:00 +0000

Proposed Amendments to the Sentencing Guidelines Speaking at a March 14 hearing in Washington, D.C., the Appraisal Institute urged a federal judicial agency to require the use of real estate appraisals when calculating loss in mortgage fraud cases. In prepared written testimony, Appraisal Institute President Sara W. Stephens, MAI, told the U.S. Sentencing Commission, “We believe the Commission should adopt a special rule for determining the fair market value of real property if the mortgaged property has not been disposed of by the time of the sentencing. However, this rule should require use of real estate appraisals prepared by qualified...

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Appraisal Institute Seeks Separation of Appraisal and AMC Fees

AppraisersBlogs — Tue, 24 Jan 2012 12:00:01 +0000

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

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AI Calls for Transparency

AppraisersBlogs — Fri, 18 Nov 2011 17:23:53 +0000

Appraisal Institute Calls for Transparency on Home Buyers’ Forms saying that consumers deserve to know what they’re paying for, the Appraisal Institute asked the federal Consumer Financial Protection Bureau on Nov. 16 to require more transparency on home buyers’ forms. In a joint letter with the American Society of Farm Managers and Rural Appraisers, AI asked the CFPB to separate appraisal fees from administration and processing fees on the settlement forms that consumers receive when purchasing a home. Created by Congress, the CFPB oversees consumer disclosure laws and is authorized to develop new forms to inform consumers and charges assessed...

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