Tagged: appraisal fees

Comment Subscriptions 8

Appraisal Fee Disclosure – Call To Action

Important – Call to Action This must be done by Tuesday July 7 The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. We feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee. Recently 23 state appraiser coalitions including the Louisiana Appraisers Coalition worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the...

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 3

Separating Appraisal Fees from AMC Fees

Disclosures regarding payments for appraisal management services versus appraisal fees On July 1, 2015, the Network of State Appraiser Organizations (NSAO) submitted a joint letter in response to the CFPB request for comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. It specifically addresses the lack of requirement to mandate disclosure to the consumer that the fee paid for an “appraisal” be clearly defined and break down what portion is being paid to the lenders’ third party appraisal management company and which portion of the fee is...

Appraiser-Client Relationship - Imagecredit Flickr - Dennis Hill 15

Don’t You Value our Relationship?

Relationships, we all have them.  And despite the efforts of Dodd Frank to destroy them, we have somehow managed to keep them. A big bank that I had a great relationship dropped me because their portal system decided there were too many appraisers last year and left me hanging. No orders for a year. Now they’re busy and want me to do appraisals. Great! But between the portal fees, underwriting charges, title surpluses, software charges, destination charges, taxes, etc. the fee works out to be substantially lower than most work I have. They asked me “don’t you value our relationship?”. I replied where...

1st Enforcement of C&R Fee Provision Louisiana Makes History - Imagecredit Flickr - Roland Tanglao 5

Louisiana Makes History – C&R Fee

First Enforcement of C&R Fee Provision: Louisiana Makes History Nearly five years after Dodd-Frank set forth rules regarding Customary & Reasonable fees (C&R) for appraisers, an agreement last week between a state board and an Appraisal Management Company (AMC) is the first evidence of enforcement. The bottom line for appraisers is that they may be finally on their way back to customary and reasonable fees. On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) issued a Stipulations and Order Memorandum (SOM) wherein Coester Appraisal Management Group, also known as Coester VMS, offers no admission of guilt but agrees...

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint - Revised Press Release - Imagecredit Flickr - Nic McPhee 1

LREAB Resolves AMC Complaint – Revised Press Release

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint Baton Rouge, LA – – On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) approved entering into a “Stipulations and Order” with Coester VMS Appraisal Management Group. The Order will resolve a pending complaint that alleged that Coester violated Louisiana law that requires AMCs operating in the state to “compensate appraisers at a rate that is customary and reasonable for appraisals being performed in the market area of the property being appraised, consistent with the presumptions of compliance under federal law” (La.R.S. § 3415.15, La. Admin Code. tit. 46,...

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 16

AMC Fined for Reasonable & Customary Fees Violation

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees As a result of a thorough investigation conducted by The Louisiana Real Estate Appraisers Board (LREAB), an adjudication hearing for an appraisal management company was held to determine if that firm is following the laws and rules pursuant to minimum reasonable and customary fees, as required by the Dodd/Frank Act and Louisiana laws and Appraisers Board rules. The case alleges the appraisal management company Coester VMS was not compliant with the state’s AMC laws and...

Truth-in-Lending Act - RESPA Ingetraged Disclosure - TRID Coming Soon Imagecredit Flickr - Dennis Skley 1

TRID Coming Soon Your Way

Appraisers and others, TRID is coming to mortgage lending on Aug. 1, 2015. In case you have not been paying attention to new aspects surrounding your typical measuring buildings and writing reports on a daily basis, TRID is set to become a major change in the mortgage lending process. TRID is the acronym for the ‘Truth-in-Lending Act/RESPA Integrated Disclosure’ process that applies to every mortgage loan as of 8/01/15.  It was part of the Dodd-Frank Law, with power given to the CFPB agency to devise the rules, forms and process. The intent is to consolidate and simplify processes that have...

Unintended Consequences & Regulatory Issues Facing the Real Estate Appraisal Profession 4

Unintended Consequences of the Dodd-Frank Law and Potential Remedies

For well over a year, the Columbia Society of Real Estate Appraisers and five other nonprofit appraiser groups have been working on an industry paper entitled Regulatory Issues Affecting the Real Estate Appraisal Profession (subtitled: Unintended Consequences of the Dodd-Frank Law and Potential Remedies). The paper is aimed at informing lawmakers of some of the unintended consequences of the Dodd-Frank law as it relates to appraisers and consumers.  We hope that lawmakers will address and correct some of the issues brought to light in this paper. The Letter Over the past year, a select group of professional appraisal organizations have...

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Evolution of C&R fees – Alter Your Thinking

Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...

North Carolina Proposed Law on Reasonable & Customary Appraisal Fees 7

NC Proposed Law RE R&C Appraisal Fees

North Carolina Proposed Law Would Address Reasonable and Customary Appraisal Fees North Carolina’s House Bill 577, introduced April 2, 2015, would seek to address reasonable and customary appraisal fees. Some of the proposals in the Bill would: Require the NC Appraisal Board to publish a “schedule of customary and reasonable rates of compensation for appraisals based on the market area where the real property is situated.” Establish rates by fee studies that would exclude assignments ordered by known appraisal management companies. Require rates to be “measured by the net compensation amount received by the appraiser.” Allow for payments above the...

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