Tagged: ASC

USRES AMC incompetence 20

AMC Incompetence in Appraisal Management

I’m told USRES routinely sends orders to out of state appraisers for orders in areas they don’t work in. Is this indicative of the Home Point Financial “We care” motto? ATTN: Executive Leadership Gentlemen, see attached copy of an Alabama appraisal order placed by your AMC, USRES. Among our many other efforts on behalf of appraisers and promoting appraisal quality, we periodically communicate directly with lenders that use AMCs. We do this to make sure they are aware of any substandard practices or services that may be offered in their name. This particular issue is not an isolated instance. Though...

Competitors on State Appraisal Boards - NSAO Supports HR 3619 6

Competitors on State Appraisal Boards

Phil Crawford has a new Voice of Appraisal show. This is one of the best shows Phil has ever done. He touches on issues with Bifurcation, Board competitors and even mentions VaCAP and our “Other Side of Things” article that received a lot of attention on Appraisers Blogs last week. Phil encourages support for VaCAP President Pat Turner to be appointed to the Appraisal Standards Board. The show is 36 minutes, so please take the time to listen. You might even get a good laugh out of some of the humor displayed. Listen to the show below. Board Competitors? VaCap,...

Committee Passes H.R. 3619 - Requires AMCs to Disclose their Fees 4

Committee Passes H.R. 3619

H.R. 3619 has passed out of committee and is now sitting in the US House for consideration. H.R.3619 would amend the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to provide the Appraisal Subcommittee with the authority to modify annual registry fees for appraisal management companies, to maintain a registry of trainees and charge a lower trainee registry fee, and to allow grants to States to assist appraiser and potential appraiser compliance with the Real Property Appraiser Qualification Criteria and would require AMCs to disclose their fees. The NCUA Quadrupled The Appraisal Threshold For Nonresidential Real Estate Loans By a 2-1...

Existing Regulatory Burden on Appraisal, a Proven Failure- System Reform 6

Appraisal Reform or System Reform

It is my hope that the Subcommittee on Housing, Community Development and Insurance consider long-term impact. The existing regulatory burden, a proven failure, may insure a repeat of the past. The body of a letter to the U.S. House Committee on Financial Services about systems reform. Appraisal reform or Appraisal industry reform? It is critical to understand that ‘appraisal’ does not equal ‘valuation’, or risk analysis, or anything else.  It is a precise definition of a nebulous product. The current U.S. House Committee on Financial Services is asking the question: “What’s Your Home Worth? A Review of the Appraisal Industry.” I believe it is...

Bill Requires AMC to Disclose their Fee and Fee Paid to the Appraiser 12

Full Transparency in Fee Disclosure

Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the appraiser by the AMC… HB 3619 has been referred to the House Financial Services Committee. VaCAP has learned over the weekend that HB 3619 has been introduced in the US House of Representatives. HB 3619, short titled “Appraisal Reform Act of 2019” amends the Financial Institutions Reform, Recovery and Enforcement Act. The main change to  FIRREA deals with appraisal management company and appraiser trainee registries and the addition of a member of the Veterans Affairs on the Appraisal Subcommittee. The bill also modifies Section 2603,...

North Dakota Appraisal Waiver Granted 8

North Dakota Appraisal Waiver Granted

News ‘hit the fan’ a few days ago that the Appraisal Subcommittee (ASC) granted the requested waiver to North Dakota, but only for ONE YEAR, not the FIVE that was requested. What does this mean? A. It does not apply to ‘all’ appraisals. B. It applies to portfolio (in-house) loans granted by lenders, NOT to loans which eventually will be re-sold to the GSE’s or other agencies – which will require a fully compliant appraisal signed by a licensed appraiser. C. The ND ‘waiver’ appraisals still must comply with USPAP, but the appraisal does not need to be signed by...

More Bankruptcies, AMC Bounced Checks, & Appraisal Waiver Granted... 6

Bounced Checks, Bankruptcies & Waivers

VaCAP has learned that another AMC might be having financial difficulties. There are conversations currently taking place in two appraiser groups on Facebook. The discussions revolve around bounced checks from an appraisal management company. The comments are varied and some are stating they are having no issues with this particular appraisal management company when it comes to payment. Others are stating invoices are past due from April and late payments have been the norm with this amc recently. One commenter stated their bank has issued a hold on checks from this amc. Then there is the original post from an...

Review Appraiser Flawed Review... Phony Complaint Against Appraiser 14

Phony Complaint Against Appraiser

…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...

Many Appraisers Will Not Work for Appraisal Management Companies 6

Devastating Impact of a Blanket Waiver

Appraisal management companies do not understand the nuances of the appraisal profession, nor do they understand the challenges many rural properties bring. The Virginia Coalition of Appraiser Professionals has submitted an official comment to the ASC opposing the State wide appraisal waiver request in North Dakota. VaCAP has submitted a public comment expressing concerns over the much larger consequences in allowing such a request. A blanket waiver of appraisals up to $500,000 for a 5 year period will have a devastating impact on housing, not only in North Dakota, but across the country. We envision a snowball effect with other...

No Shortage Exists - Bankers Data Proves No Appraisal Shortage Exists 9

No Shortage Exists

No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...

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