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...
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....
…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...
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 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...
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....
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...
The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...
Yet another third party huckster has entered into the real estate appraiser and appraisal arena. It’s that time again! Yet another third party huckster has entered into the real estate appraiser and appraisal arena. Apparently motivated by pure altruism. We identified a need in the marketplace to address a common problem that lenders are regularly challenged with in providing accurate appraisal quotes and then ensuring pricing on the Loan Estimate is consistent and compliant,” stated Vladimir Bien-Aime, president and CEO at Global DMS. (I LOVE this guy, he writes like me!) Global DMS Launches SnapVal to Provide Instant, Accurate, Guaranteed...
I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. We knew that when we joined with others in signing the letter. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy...
