We often receive calls from appraisers who have been blacklisted by a lender they do no direct appraisal work for. Typically, the story is the same. They are being dropped from an AMC panel that has given them a lot of business because the AMC found out one of the bigger secondary market loan buyers/lenders has blacklisted the appraiser. This is a lender they do not work for and/or haven’t done any work for in years. The blacklisting is based on some alleged issue with an appraisal done for another client and usually involves a review of the old appraisal...
Late yesterday afternoon a bill was introduced in the House of Representatives that would alter the mortgage process and ultimately the way millions of Americans receive a mortgage. HR 1108 would eliminate the need for an appraiser to appraise a home prior to the funds being disbursed to the
In response to Frank Garay and Brian Steven’s commentary (see video below), on the lawsuit against TriMavin AMC over alleged appraisal independence violations, an anonymous commentator posted the following: There are a number of posters here who need to re-take their CE classes including the moderators. Here are the reasons the entire industry is severely broken. I mean from the Realtor to the Appraiser to the Mortgage Lender. First of all HVCC sunset folks – back in 2010. It was replaced with AIR (Appraiser Independence Regulations) and the Dodd Frank Act. Cannot tell you how irritating it is to me...
Former Chief Appraiser Sues Appraisal Management Company Over Alleged Appraisal Independence Violations With respect to appraisal management companies (AMCs), based on the large volume of appraisal regulatory and legal matters that we track, I feel comfortable stating that there is no material governmental enforcement of the appraisal independence rules adopted in the Dodd-Frank Wall Street Reform and Consumer Protection Act (or in the earlier rules adopted by the Federal Reserve Board in 2008 as part of Regulation Z). Neither the Consumer Financial Protection Bureau nor any state attorneys general have undertaken any significant investigations or taken any significant legal actions...
In April of 2013, Fannie Mae released its updated Selling Guide. “Appraiser Independence Requirements” and “Appraiser Selection” sections were updated…
Hire an Independent Property Appraiser for an Unbiased Evaluation Dealing in real estate requires a lot of knowledge about property markets. Not all buyers and sellers are well-acquainted with such matters. In such cases, it becomes important to hire a third party like a property appraiser who holds expertise in such matters. Why an Appraiser? Involving a property appraiser brings an element of impartiality in property dealings. When you deal directly with the opposite party
NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...
February 20, 2013 – Serious problems in the residential appraisal process must be addressed in order to restore confidence in the residential real estate market and to establish a foundation for sustainable growth of the U.S. economy, according to a new white paper from the National Association of Home Builders (NAHB). Appraisals are regulated by the states, so standards and requirements vary greatly, resulting in a system that is inconsistent, confusing and does not serve consumers well. The white paper, “Comprehensive Blueprint for Residential Appraisal Reform,” addresses these problems. It is the work of an Appraisal Working Group formed by...
Lately, there has been some controversy surrounding the announcement of CoesterVMS implementation of a flat fee appraisal structure which went into effect on January 1. The announcement appeared on CoesterVMS Blog on January 7: CoesterVMS, a nationwide appraisal management company, has implemented the appraisal industry’s first ever flat fee model for residential appraisals. Under the flat fee model, which took effect on January 1, 2013, all conventional appraisals for mortgage lenders are priced at $450 while FHA appraisals are $475*. Customarily, appraisal management companies utilize a tiered fee structure, whereby prices are determined based on the property type or the...
The National Association of Independent Housing Professionals (NAIHP) led by Marc Savitt is petitioning the Consumer Financial Protection Bureau and is asking those harmed by the Interim Final Rule on Appraiser Independence to sign and forward the online petition. To Consumer Financial Protection Bureau (CFPB), Richard Cordreay, CFPB Director: Allow NMLS loan originators to order appraisals directly from appraisers Consumers and small business are being significantly harmed by the Interim Final Rule on Appraiser Independence. Consumer costs have increased by over 2.8 Billion dollars a year; thousands of small business residential appraisers have gone out of business, as the rule diverts...
