Tagged: CFPB

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Minimum Requirements for AMCs

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

Proposed Rule for AMCs 0

Proposed Rule for AMCs

Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Subcommittee / Appraisers News

Online Petition to Make a Difference in Customary and Reasonable Appraisal Fees 5

Customary & Reasonable Appraisal Fees

A Cost-Plus fee structure will allow the Customary and Reasonable Fee provision, a component of Appraiser Independence, to be more readily adopted. Fellow Professional Appraiser, I am asking you to take a moment from your busy day to PARTICIPATE in an important industry effort. That issue is referred to within Title XIV of the Dodd-Frank legislation as “Customary and Reasonable Fees”: CUSTOMARY AND REASONABLE FEE In General – Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

American Guild of Appraisers Member John Dingeman Reinstated from Chase "Black List" 2

John Dingeman Reinstated from Chase “Black List”

American Guild of Appraisers Member John Dingeman Reinstated from Chase “Black List” NEW YORK, Jan. 15, 2014 /PRNewswire-USNewswire/ — After a fight that lasted more than fifteen months, involving Chase Manhattan Bank, the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC), American Guild of Appraisers (AGA) member John Dingeman was vindicated when Chase agreed to reinstate him to be eligible for appraisal assignments.  AGA is an affiliate of the Office and Professional Employees International Union (OPEIU), AFL-CIO. Dingeman was placed on Chase’s “Black List” in May 2012 after he refused to release information...

AGA / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / CFPB

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Mortgage Disclosure Rule Alters Appraisal Fee Reporting

The Appraisal Institute on Dec. 17 finalized its review of the Consumer Financial Protection Bureau’s 1,888-page final rule on Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act and the Truth in Lending Act, and noted several provisions that impact real estate appraisers and how appraisal fees are reported. The rule, which takes effect Aug. 1, 2015, mandates the use of two new disclosure forms, the Loan Estimate (which replaces both the Good Faith Estimate and the initial Truth in Lending Disclosure) and the Closing Disclosure (which replaces both the HUD-1 and the final Truth in Lending Disclosure). It...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

Former Chief appraiser sues AMC 8

Former Chief Appraiser Sues AMC

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

Appraiser Complaint Forms 0

AI Advocates for Issue-Specific Appraiser Complaint Forms

The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 28 to the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Comptroller of the Currency expressing concern about the broad reach of a proposed Interagency Appraisal Complaint form. The agencies intend to provide a copy of the form to individual complainants, who, in turn, will return to the agency for information gathering and potential referral. In its letter, AI and ASFMRA expressed concern that the proposed form may not be the most effective approach and instead recommended complaint forms...

AI / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal News / Appraisal Organizations

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Read That Agreement Before You Sign or Leap

Having the most unfair agreement will cause the lender or AMC to lose those appraisers I recently ran across the provision below in a new contractor agreement between an AMC and its panel appraisers, when one of LIA’s insured appraisers asked me to take a look at the agreement. The contract contained the average indemnification provision found in most unfair AMC contracts in which an appraiser promises to defend and reimburse the AMC for “any and all liabilities, damages, costs and expenses (including all legal fees) arising out of or relating to any claim, action, suit, complaint, liability, damage, or other...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

NCRC Statement on CFPB Appraisal Rules 0

NCRC Statement on CFPB Appraisal Rules

Washington, DC Jan 18, 2013 – Today, in reaction to the Consumer Financial Protection Bureau’s (CFPB) release of new appraisal rules, NCRC President and CEO John Taylor made the following statement: “The CFPB’s new appraisal rules promote transparency and fairness for consumers. In a step that NCRC has long called for, all consumers will now receive copies of appraisals and automated valuation model (AVM) reports and will be able to check them for errors. Further, consumers and industry alike will benefit from the use of responsible valuation professionals in high cost loan origination. We are very pleased that the CFPB...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Automated Valuation Models

Consumer Access to Appraisal Report 0

CFPB Adopts Rule to Improve Consumer Access to Appraisal Reports

CFPB Rule gives consumers additional rights to information on how a home value is determined Washington, D.C., Jan 18 2013 – Today the Consumer Financial Protection Bureau (CFPB) adopted a new rule that requires mortgage lenders to provide applicants with free copies of all appraisals and other home-value estimates. The rule will ensure that consumers can receive information prior to closing about how the property’s value was determined. “This rule will guarantee consumers can receive important information on how a lender determines the value of the home,” said CFPB Director Richard Cordray. “Having this information available promptly makes it easier...

Appraisal / Appraisal News / Appraisers News / CFPB / Consumer Financial Protection Bureau / Dodd-Frank Act / C&R Fees

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