Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...
The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...
Missing the Good Old Days Does anybody miss the good old days of having to deal with the mortgage broker? After spending about 53 minutes on the phone with an appraisal management company, who will remain nameless, I am almost missing the good old days myself. I originally called, because the appraisal management company called to see if I would take a forensic retrospective review for a new client they just acquired. This of course is a Fannie Mae client, and any of us who have dealt with Fannie we know there is a specific format, guideline and style in...
Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...
Dear Appraiser Colleagues, Awhile back, you responded to a request from VaCAP to supply your e-mail address to participate in an upcoming Customary and Reasonable Fee Survey to be conducted by the Virginia Center for Housing Research and the Virginia Tech Program in Real Estate. This communication is to notify you of the survey’s eminent release. Please look for it to be sent to you via e-mail in the next couple of days. Your participation in the survey is vital to the success of this endeavor. Please take the few minutes necessary to complete the survey; it should only take...
Appraisers to be paid within… It is all-too-rare that we hear positive news regarding the appraisal profession. There is an awful lot of complaining that goes on, most of it justifiable, but little good news that gets shared. Part of the problem is that there is no central source for information regarding our profession which appraisers might utilize in order to find out what is going on across the country and affecting our profession, and could be used to enhance our industry and our citizens in our own state. From what I have seen, most of any good news is being...
The good appraisers are leaving mortgage appraising as fast as they can. Thus far the housing industry has been applying “Band-Aid” solutions to the bigger real estate crisis. There are several problems going on at the same time, all contributing to the big picture, which is bleak to say the least. One true crisis in the real estate industry is an “information crisis.” This information problem, trickles down to appraisals, lenders, and ultimately, mortgage investors. Standardization, national guidelines, and disclosures are the only way back from this nightmare (i.e. the RESPA disclosure. One fee on the good faith estimate for...
One of the hottest topics right now in the appraisal world is that of non-lender work. I am probably asked a question concerning non-lender appraisals a couple of times per week, at least. “How do I do more work for attorneys?” “How do I go about marketing to home owners?” “I want to work with more real estate agents, but I am not sure how to garner their trust.” Okay, so that last one was not a question, but you get the point. Financial appraisal work through AMCs or local banks has slowed a great deal over the past few...
…hidden costs introduced by AMCs… Thinning wallets and dwindling fees for work performed are nothing new for the appraisal community. Yet in their latest income-reducing move, AMCs have sparked an outcry by requiring appraisers to foot the bill for additional services. These charges are further cutting into appraisers’ fees, which already suffer from AMC management fee deductions. Recently, FREA uncovered three hidden costs being introduced by AMCs – which of these have you experienced? Technology Usage An increasing tendency among AMCs is the passing of technology fees on to appraisers. When an AMC orders a home valuation, the appraiser must...
In 2012, AI requested the removal of the references to the AOs and FAQs from the Commission’s regulations…. On April 8, the Maryland Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors completed action on rulemaking that removed the Advisory Opinions and Frequently Asked Questions of the Uniform Standards of Professional Appraisal Practice from being incorporated by reference into the state’s appraiser licensing and certification laws. The move addresses the Appraisal Institute’s long-standing concerns about increased regulatory burdens placed on professional appraisers. Prior to this rule change, the AOs and FAQs were considered by the Commission to be...
