Tagged: appraisal threshold levels

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

What Are You Waiting For? Only 179 Comments...Please Comment Now! 13

What Are You Waiting For?

Please comment now! VaCAP sent out a “Call to Action” a month ago to comment on the proposed increase in the appraisal threshold to $400,000. As of this writing, only 179 comments have been received. This is our future, please comment now! Comments must be received by February 5, 2019. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property...

Ulterior Motive in Raising De Minimus 20

Ulterior Motive in Raising De Minimus

…raising de minimus shenanigans being promoted… Appraisers, a couple of weeks ago, I sent out a message about a Fee/TT quote conversation I had with an AMC clerk. I received a number of responses from appraisers across this fruited plain who said often they will receive Fee/TT quote requests for the SAME property from MULTIPLE AMC’s. That corroborates stories I hear from appraisers I talk with at conferences. The entire AMC situation is a giant time-wasting game that really doesn’t benefit the borrower at all, and least of all, appraisers. Lenders are the coaches in this game. Another message I received...

Proposal to End Appraisal Requirement on Home Sales of $400k or Less 50

Proposal to End Appraisal Requirement

Regulators’ Proposal to End Appraisal Requirement on Some Home Sales of $400,000 and Below… The Federal Deposit Insurance Corp., the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve released a proposal that would increase the appraisal requirement from $250,000 to $400,000, meaning that certain home sales of $400,000 and below would no longer require an appraisal. According to data provided by the FDIC, the agencies estimate that increasing the appraisal threshold from $250,000 to $400,000 would have exempted an additional 214,000 residential mortgages at regulated institutions from the agencies’ appraisal requirement in...

Waiving Appraisals, Lowering Appraisal Standards, & Raising De Minimis... 13

Waiving Appraisals & Lowering Appraisal Standards

Freddie getting aggressive in waiving appraisals & promoting appraisal free mortgages… Appraisers, Yes, I have a ‘dog in the fight’ with this article, as I have been an Appraisal Institute member since 2003 (along with other association memberships since). But this article provides explanations about changes to the appraisal process I have not seen elsewhere. Excerpt from “Dodd-Frank rollback weakens appraisal standards“ They started to evaluate whether they wanted to raise that appraisal threshold level from $250,000 to some figure… They left it untouched at $250,000 for residential, but they have increased the commercial real estate appraisal threshold level just in the...

FRT Not Reflecting the Majority of the Mortgage Lending Environment 6

Watering Down FRT Definition

Definition of FRT simply does not reflect the majority of the mortgage lending environment… So what exactly is a “federally related transaction”, or FRT for short? Wait, that’s not the right question. Let’s start here: What is NOT an FRT? It’s not a mortgage loan insured by the Federal Housing Administration. It’s not lending underpinned by the Department of Veterans’ Affairs home loan program. It certainly isn’t a loan that’s sold to a Government Sponsored Enterprise (or GSE), like Fannie Mae or Freddie Mac. Just considering a loan for sale to those two entities is enough to fall outside the...

Appraisal Thresholds Raised $500K. How Long Before Its Raised for SFR? 12

Appraisal Thresholds Bordello

Anyone wants to place a wager on how long before appraisal thresholds are raised for SFR? Retirement, with a part-time job working as a bouncer at a bordello in the Nevada desert is beginning to look appealing. Activity there is similar to what appraisers are experiencing these days. From the article: “The FDIC board of directors today (Mar. 20, 2018) approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000…” While the individual 1-4 unit investment properties are being kept at $250,000, would anyone like to place a wager on how long...

Community Bankers Voice Their Concern About Real Estate Appraisal 19

Bankers Concerned About Appraisals

Community bankers said appraisals are becoming a concern… A survey was distributed by state banking regulatory agencies in April and remained open through July. More than 600 community bankers from across the U.S. lent their voices to this year’s survey, and those views are captured in this volume. Responses are summarized and presented in following five major areas: Local market conditions; regulation and supervision; small business lending; management structure and succession planning; and technology. The responses provide context for the data gathered through the survey and highlight some of the dierent challenges faced by community banks in different states. The...

Appraisal Threshold on Commercial Loans May Change 4

Commercial Appraisal De Minimis Proposal

Proposal To Increase The Appraisal Threshold On Commercial Real Estate Loans The Federal Financial Institutions Examination Council’s Joint Report to Congress said the federal banking agencies are developing a proposal to increase the threshold for requiring an appraisal on commercial real estate loans from $250,000 to $400,000. The report did not propose changes to the current residential real estate threshold of $250,000. In addition, the agencies recognize that appraisals can provide protection to consumers by helping to assure the residential purchaser that the value of the property supports the mortgage amount assumed. Overall, the agencies believe that the interests of...

Appraiser Shortage Myth Used to Raise De Minimis Value 43

Appraiser Shortage Myth Used to Raise De Minimis Value

Appraisers, I know everyone is busy right now, but this cannot wait. This may be the most important blog post affecting appraisers this year. I don’t think it is an exaggeration to say that if something is not done, it really COULD lead to the end of ALL residential appraisers for federally regulated transactions under $500,001. FFIEC under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), is considering raising the de minimis lending level from $250,000 to $500,000, because the local community banks are complaining that they cannot find enough appraisers in rural America to handle the volume! If...

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