Mortgagee letter on choosing FHA appraiser, AMC &/or 3rd party fees… Does HUD have a Better Understanding of the Role of AMCs? Recently an old HUD/ FHA mortgagee letter has resurfaced. The mortgagee letter, 2009-28 has to do with choosing a FHA approved Roster Appraiser and Appraisal Management Company and / or Third Party Organization Fees. This mortgagee letter specifically states “the fee for the actual completion of an FHA appraisal may not include a fee for management of the appraisal process any activity other than the performance of the appraisal.” This mortgagee letter was written prior to the Final Rules and...
Amendments to Sales Contract & Updates to the Appraisal… Fannie Mae recently issued the following: Currently, we require the lender to provide the appraiser with all amendments made to a sales contract, including amendments that are made after completion of the appraisal. With this update, we have clarified when the appraiser must be provided with updates to the sales contract and circumstances that warrant updates to the appraisal. For example, if the contract is amended in a way that affects the description of the real property used by the appraiser, then the lender must provide the updated contract to the...
Very often the public records are dead wrong… Appraisers, We all know Fannie Mae (FNMA) has their Collateral Underwriting (CU) report scoring system after the .xml file of the report is submitted through the Uniform Collateral Data Portal (UCDP) portal used by both GSE’s. This system of theirs is used to ‘score’ an appraisal for a loan quality rating, and it’s also used to provide a lender with a guarantee of relief from a FNMA loan buy-back demand, if the report ‘scores’ a number of 2.5 or lower. We’ve previously discussed how that can be manipulated by a lender or an...
Foreign entities do not get a voice in what legislation is introduced… Let’s think about this with an open mind… More states are introducing bills concerning AMC legislation, more specifically how AMCs will conduct business. Even states with existing AMC legislation are introducing stricter, more precise legislation. Why is this happening in all 55 jurisdictions? States do not want to interfere in how a company or industry conducts business, but when practices are so abusive that it harms small businesses and consumers, they have little choice. States have the obligation to protect their citizens and businesses that contribute to the...
These forms were “designed” to be used for those specific purposes… Appraisers, Earlier this week, I discussed the following about some lenders requesting a type of property inspection to be completed on a form “Not Designed” for the specific property type: Original observation discussed earlier this week: Read the highlighted sentence. Read the highlighted sentence again. According to a regional bank in my area, via info from their AMC, “thousands” of Manufactured Home appraisals have been done on the 2055 form. Do you do that, just because someone – who just wants to “make a sale” – tells you to...
Slow pay reputation AMCs and Ponzi scheme payment process… Folks, Through several of the ‘media sources’ I read recently, I’ve learned that “a particular AMC” based on the west coast has a slow pay reputation. As so often happens with low echelon AMCs with few clients, when business slows down, their payment process becomes a Ponzi scheme. Ultimately they go out of business. I currently have an outstanding report with that AMC, but the payment due date to me is March 7. So I’m respectfully withholding their name publicly from others, until and unless they don’t pay me on time....
Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...
Disciplinary action against 2 AMCs for late payment & operating without license You just have to shake your head at what they try to pull off! At the February 14th Virginia Real Estate Appraisers Board Meeting, Independent Settlement Services and Landmark Network were each disciplined for violations of Virginia AMC Regulations. Independent Settlement Services was disciplined for not disclosing prior disciplinary action in North Carolina. North Carolina audited them and found only 75 times out of 579 appraisals, they paid appraisers within 30 days as required by North Carolina law. The state of Nebraska also fined Independent Settlement Services for...
Congress, cut FNMA loose from conservatorship and let them sink or swim… Every day I tend to agree more and more that we are facing an uphill battle against corporate America. Then I remember that as a former Marine, I’m supposed to be ‘ok’ with uphill battles. We make do with what we have, not necessarily what we want or need. Add to this most, if not all of our Congress from both Senate and House. Some isolated exceptions but most either don’t care or encourage the weaknesses in the financial system for their own gain. There is a reason...
Allowing associated trainee appraisers to complete unsupervised inspections… Appraisers, and others, A ‘significantly large’ nationwide AMC has notified it’s vendor appraisers that certain lenders contracted with this AMC will now accept appraisal reports signed by properly trained (and presumed properly approved by the State) Trainees as the ‘Appraiser.’ This follows the Jan. 31, 2017 FNMA announcement that they will accept reports signed by Trainees. So far, I have not seen any similar announcement from FrMAC, FHA, VA, or USDA, or any other specific lender. The AMC’s message to their appraiser panel is below. NOTE: This memo says the Trainee is...
