Tagged: CFPB

CFPB Investigations in Alleged Appraisal Discrimination 25

CFPB Investigations in Alleged Appraisal Discrimination

The Consumer Financial Protection Bureau (CFPB) has started investigating alleged appraisal discrimination. This is a new development, as federal investigations had so far exclusively been by HUD. The CFPB is an aggressive investigator, and AMCs, large firms and lenders should be wary. For the last year, 40% of my legal work has been occupied by issues concerning alleged discrimination – balanced between representing parties in fair housing investigations and helping clients improve compliance and decrease risk. It’s the CFPB that makes me most anxious for clients in the future. I addressed some of the details of what I’m seeing in...

Protect Yourself, Ins & Out of Bias & Discrimination Webinar & Forum 5

Protect Yourself Against Racial Bias Claims

Free webinar on how to protect yourself against discrimination claims on 6/30/22, and today there will be a forum on “Racial Bias in the Home Appraisal Process”… OREP is sponsoring a free webinar on how to protect yourself and your business against discrimination claims. Leading trial attorney Craig Capilla has handled nearly 1,000 appraiser cases in his career and has been on the frontlines defending appraisers from lawsuits, state board complaints, and now, HUD Fair Housing (Discrimination) complaints. Capilla began his legal career working for Illinois’ professional regulation agency as a real estate prosecutor and since then has become one...

AEI Research Critique of Freddie Mac's Misleading Appraisal Gap Report 3

AEI Research Critique of Freddie Mac’s Misleading Appraisal Gap Report

More great research from AEI. This is an analysis of Freddie Mac’s misleading and basically defamatory paper on Appraisal Gap. When government related entities release misleading information like this they are attacking and defaming real estate appraisers. The hate real estate appraisers have received because of this paper and Andre Perry’s paper is relentless. Another problem with releasing misleading data and conclusions is that it actually hurts the people they are trying to help. Facts show that the real cause of the wealth gap between blacks, whites and Latinos is the income gap. It has nothing to do with appraisals...

Bias in Automated Valuation Models 10

Bias in Automated Valuation Models

The CFPB is reviewing bias in Automated Valuation Models (AVMs). The proposed rules are a joint effort by the Consumer Financial Protection Bureau, the Office of the Controller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Federal Housing Finance Agency. These agencies are concerned AVMs may reflect bias in design and function. The mathematical models rely on biased data resulting in inaccurate valuations. Basically the agencies are stating historical data going back to redlining is built into these models and do not reflect current market data. Remember markets are not static and are...

Secret HUD Meeting on Valuation Bias... Input of Appraisers Is Unwanted 11

Secret HUD Meeting on ‘Appraiser Bias’

The exclusion of the appraisal profession from events looking at valuation bias sends the message – intentional or not – that the input of appraisers is unwanted by those seeking to address issues relating to valuation bias… This was in a news release put out on Aug. 2, 2021 by the American Society of Appraisers which reveals the ‘secrecy’ behind the government’s efforts to attempt to continually help smear real estate appraisers: “RESTON, Va., Aug. 2, 2021 /PRNewswire/ –The Department of Housing and Urban Development (HUD) held a virtual event today looking at bias issues surrounding the home valuation process....

Racial Bias Narrative to Remove Appraisers From the Lending Equation 10

Racial Bias Narrative to Remove Appraisers

…the racial bias narrative will be what is utilized to remove appraisers from the lending equation… Removing us will finally put the FOX completely in charge of the HEN HOUSE…this entire narrative could very well end up costing us all, our way to make a living… Unfortunately, Professional Appraisers have no organized voice and I don’t see that we ever will. There is no one to defend us. And that has been used against us for years. After all that Appraisers have been through over the last 15 years, the racial bias narrative and the allegations of racial discrimination in...

Could the CFPB Eliminate AMCs? End of AMCs Fast & Cheap Mentality? 10

Could the CFPB Eliminate AMCs?

Will this be detrimental to appraisal management companies that operate under the fast and cheap mentality?… Let’s face it, the appraisal management company will not survive with quality appraisals at a reasonable and fair fee… The Consumer Financial Protection Bureau is seeking public comments on the proposed rules for a Qualified Mortgage. The proposed rules require the lender to season the mortgage for 36 months before they can sell it to Fannie or Freddie. What that means is the lender will own that loan for 3 years. Fast forward if the new rule goes into effect… The lender will be...

CFPB Wants to Eliminate the Debt to Income Requirement - Not AGAIN 5

Playing Fast and Loose With Credit?

CFPB is moving forward with proposing to eliminate the Debt to Income requirement… Appraisers, prepare yourself for what we are about to share. The short sighted proposal is simply nonsensical from every angle. The Consumer Financial Protection Bureau wants to eliminate the Debt to Income requirement on Qualified Mortgages. You may recall this was proposed a while back and most of the profession objected strongly. Letters, emails and phone calls were made and this absurdity went away. Earlier today CFPB Director, Kathy Kraninger announced the CFPB is moving forward with proposing to eliminate the Debt to Income (DTI) requirement and...

Hard Fixed Appraisal Fee in TRID - Possible Changes by CFPB 19

TRID – Possible Changes by CFPB

For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser… Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans. Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments....

Lenders Want to Eliminate DTI Cap! What Could Go Wrong? 20

Lenders Want to Eliminate DTI Cap!

No DTI CAPS – What could go wrong? Well, the insanity continues. HousingWire is reporting that a coalition of lenders and trade groups are calling on the CFPB to eliminate the debt to income cap on all qualified mortgages. Yes, you read that right. Lenders want to eliminate the debt to income cap to allow more loans to be originated. They claim by using alternative factors to determine risks, more low income borrowers can obtain a mortgage. Mortgage Bankers Association President and CEO Robert Broeksmit stated: With respect to the 43% DTI threshold, it makes little sense to commit to a rigid requirement...

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