de minimis - Appraisers Blogs

Reconciling the Erosion Within My Profession

Maureen Sweeney — Wed, 09 Sep 2020 12:30:02 +0000

The continued reliance of unregulated aggregators and bifurcated products continues to erode the public trust at the expense of discarding the profession specifically intended to promote the public trust. How does this protect the public?… On June 14, 2005 Steve Jobs told a class of graduates, “you can’t connect the dots looking forward; you can only connect them looking backward” Around the same time, I was appointed as the sole residential member of the appraisal licensing board of my state. Little did I realize that this 2005 governor-appointed position would eventually lead me to sharing a stage in 2018 with...

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FIRREA Under Attack!

VaCAP Board — Thu, 13 Feb 2020 13:30:15 +0000

…the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for which an appraisal is required… Congresswoman Maxine Waters and Congressman William Lacy Clay request a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. The letter to Gene Dodaro, Comptroller General, Government Accountability Office, addresses threshold increases, regulatory exemptions, appraisal waivers, the North Dakota appraiser certification waiver and evaluations in lieu of an appraisal. It is clear the Chairwoman of the House Financial Services Committee and Subcommittee Chairman on Housing, Community Development and Insurance...

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Low Rates and Plentiful Appraisal Waivers

Dave Towne — Mon, 10 Feb 2020 13:30:54 +0000

The graph below comes from Len Kiefer, the data guru at Freddie Mac. Are we due for even lower rates? Who knows. But they have been lower not long ago. Theoretically, appraisers should have been really busy since about November 2018 through this past year. Were you? Me, not so much, but I don’t work for many AMC’s either. The fact that the GSEs and others have diminished the value of getting an appraisal done has adversely impacted our work. Waivers are plentiful now, and the raising of the de minimus threshold to $400K for non-GSE loans has reduced the...

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Loans Affected by the De Minimus Increase

Dave Towne — Fri, 11 Oct 2019 12:30:57 +0000

NCUA is advocating for an increase in the de minimus to $400K for loans provided by Credit Unions… The $400,000 de minimus is now ‘official’ but it doesn’t apply to most appraisals. Here’s an article from HousingWire, published on 10/8/2019, which correctly states when this change took effect, which you should read. From the article: Now, it’s important to note that the new rules do not apply to loans wholly or partially insured or guaranteed by, or eligible for sale to, a government agency or government-sponsored agency. What that means is that loans sold to or guaranteed by the Federal...

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Appraisal Waiver Questioned by Legislators

VaCAP Board — Tue, 01 Oct 2019 12:30:01 +0000

Late Friday afternoon, VaCAP learned the Financial Services Committee Chairwomen. Maxine Waters and Senator Sherrod Brown, Ranking Member of the Senate Committee on Banking Housing and Urban Affairs, sent a letter to the Appraisal Subcommittee Chairman Arthur Lindo inquiring around the circumstances of the North Dakota Appraisal Waiver that was granted a few months back. The exact verbiage used in the letter to describe the waiver was “unprecedented with minimal justification.” This speaks volumes as to their concern. Congress has repeatedly recognized the essential role that appraisals play in both safety and soundness and consumer protection. That is why it is...

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The Collective Rot

Frederick E Rossiter — Wed, 25 Sep 2019 12:30:27 +0000

Over 11,000 appraisers signed that petition… The US Congress completely ignored it and, as a result, The Great Real Estate Depression followed. Déjà vu: Or is it Déjà Poo (I’ve heard this crap before)? The Collective Rot Growing Within the Shadows of the Great Real Estate Depression We are just 11 years past the beginning of the Great Recession. Some estimate the US suffered a $14 trillion loss in wealth. Others estimated the loss as high as $21 trillion. This event is more commonly referred to as The Great Real Estate Depression by those of us who are or were in the real estate industry...

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Bringing Evaluations Under USPAP’s Umbrella

ICAP Board — Fri, 06 Sep 2019 12:30:43 +0000

Evaluations: Concept Paper, Webinar, Public Meeting In early August, The Appraisal Foundation announced that the The Appraisal Standards Board would be considering adopting standards for evaluations in the Uniform Standards of Professional Appraisal Practice (USPAP). On September 3, 2019, they announced three opportunities to learn more and share your insights. Concept Paper The Appraisal Standards Board is seeking your feedback on the concept of developing standards for performing evaluations in USPAP. Submit your comments to ASBcomments@appraisalfoundation.org. The comment period closes on October 11, 2019. Read the evaluations concept paper here Webinar Wayne Miller, chair of the Appraisal Standards Board, and...

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De Minimus Impact on the Appraisal Industry

Dave Towne — Thu, 22 Aug 2019 12:30:53 +0000

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

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FDIC Says NO to Appraisals

VaCAP Board — Wed, 21 Aug 2019 12:30:22 +0000

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...

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Federal Agencies Changing FIRREA

VaCAP Board — Sun, 18 Aug 2019 12:30:47 +0000

VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraisal waivers in North Dakota. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies...

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Committee Passes H.R. 3619

ICAP Board — Wed, 31 Jul 2019 12:30:43 +0000

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...

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NCUA Quadruples the Appraisal Threshold

Dave Towne — Mon, 22 Jul 2019 12:30:05 +0000

Like so many things in life, the NCUA Board decision was predicated primarily on greed… This is a lot like the liar loans that infiltrated residential lending not that long ago. Appraisers, especially Commercial appraisers, I picked this info up from a message sent out by the Appraisal Institute on July 18, 2019: “The NCUA Board of Directors today quadrupled – from $250,000 to $1 million – the appraisal threshold for nonresidential real estate loans. NCUA is the National Credit Union Administration. The appraisal threshold is the loan amount below which appraisals are not required. Increasing the threshold would drastically...

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North Dakota Appraisal Waiver Granted

Dave Towne — Sat, 13 Jul 2019 12:30:59 +0000

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...

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Is Race Baked into Big Data?

Jonathan Miller — Mon, 01 Jul 2019 12:30:11 +0000

Chicago appraiser and friend (even though she calls me “fancy pants”) writes a stellar explanation of what an appraiser actual does – and what one of the panel experts got completely wrong because he didn’t understand our role in the mortgage process: Greetings Congresswoman Waters, Chairman Clay, Ranking Member Duffy, Ranking Member Gooden, and the Members of the Housing Subcommittee: My name is Maureen Sweeney, and I am a real estate appraiser. I grew up in a real estate family and lived through the savings and loan crisis of the 1980’s, which had a profound impact on my life. I...

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Commercial Appraisers Livelihood Threatened

Dave Towne — Fri, 10 May 2019 12:30:56 +0000

Commercial appraisers may want to open this link, and read it. Your livelihood is possibly threatened by the National Credit Union Administration (NCUA). You may want to send a letter to the NCUA Board of Directors. Proposed Appraisal Rule Provides Relief, Clarity As part of the NCUA’s regulatory relief agenda, the Board approved a proposed rule (Part 722) to amend the agency’s real estate appraisal requirements for certain transactions. The proposed rule would provide a measure of regulatory relief and increased clarity by: Increasing the threshold for required appraisals in non-residential real estate transactions from the current $250,000 to $1 million; Reorganizing...

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Appraisers Disappointed at Federal Agencies

Michael Ford — Tue, 26 Feb 2019 13:30:22 +0000

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...

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Feds Deny Public Hearing

VaCAP Board — Mon, 25 Feb 2019 13:30:13 +0000

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...

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Standing With Us Protecting Consumers!

VaCAP Board — Fri, 15 Feb 2019 13:30:57 +0000

…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...

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MCS Valuations (AMC) Closing Shop

Dave Towne — Wed, 06 Feb 2019 13:30:39 +0000

I saw a posting by another appraiser on a Facebook page on February 5, 2019 that MCS Valuations, based in Lewisville, TX, is closing shop. They are an AMC, and provide BPO’s and other real estate related services. The appraiser posted a letter from the company. They will not be placing any more appraisal assignments, but are asking appraisers to finish any assigned reports already in the pipeline. What’s really striking about this closure is that in 2014, MCS Valuations bought ‘components’ of CoreLogic’s associated entities that CoreLogic no longer wanted in their business! February 5, 2019 This communication is to inform...

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What If the Algorithms Are Wrong?

VaCAP Board — Mon, 04 Feb 2019 13:30:29 +0000

Algorithms are everywhere… “Algorithms decide who gets a loan, who gets a job interview, who gets insurance and much more — but they don’t automatically make things fair. Mathematician and data scientist Cathy O’Neil coined a term for algorithms that are secret, important and harmful: “weapons of math destruction.” Learn more about the hidden agendas behind the formulas.” “Algorithms are opinions embedded in code. It’s really different from what you think most people think of algorithms. They think algorithms are objective and true and scientific. That’s a marketing trick. It’s also a marketing trick to intimidate you with algorithms, to...

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