Dodd-Frank Act - Appraisers Blogs

A Cry from the Appraisal Trenches: The Fall of GSE Oversight

Guest Author — Fri, 25 Apr 2025 12:30:13 +0000

That could bring our best and brightest back to GSE lending, leveling the playing field with fairer work distribution. Picture this: a system built to protect homeowners, backed by taxpayer dollars, now teetering on the edge of betrayal. The regulatory framework governing Government-Sponsored Enterprises (GSEs) was once a fortress of consumer protection, transparency, and fairness. As an appraiser, I’ve watched this fortress crumble. The rules imposed on GSEs and their partners—our trade-off for their congressional charter—have been chipped away through years of cunning maneuvers by trade groups and stakeholder interests. What’s left is a hollow shell, far removed from the...

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The Shadowy AMC Fees Draining Billions from Homebuyers

AppraisersBlogs — Thu, 09 Jan 2025 13:30:46 +0000

The hidden costs of appraisal management companies (AMCs) in the real estate industry have faced growing scrutiny, as highlighted by a recent Business Insider article titled “The Hidden Middleman who cost homebuyers $12 billion dollars and counting.” The article examines the opaque practices of AMCs, which frequently charge exorbitant fees that can exceed the amount paid to the appraiser. As highlighted by former Appraisal Institute CEO Cindy Chance, this issue has faced significant resistance from entrenched interests, mirroring the challenges faced in other industries such as the pharmacy benefit manager (PBM) sector, which ultimately led to an FTC investigation. The...

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How Deep Fakes Have Burrowed Into Home Finance

Jeremy Bagott — Mon, 14 Oct 2024 12:30:11 +0000

Fannie and Freddie have been toiling at the coalface of “synthetic appraisals” – “black box valuations.” In the 1960s, technocrats at the Pentagon used the latest IBM mainframe computers to analyze complex data related to the Vietnam War. Planners fed punch cards into the machines and ran endless simulations, hoping to determine strategies for winning the war. In 1967, analysts finally asked the computer, “When will we win in Vietnam?” The machine’s answer: “You won in 1965.” It exposed the hubris and naiveté of those who believed computer-generated models could capture and quantify millions of complex human interactions on the...

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

AppraisersBlogs — Fri, 30 Aug 2024 12:30:34 +0000

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit. The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies...

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County Assessors’ Standards | AVM Final Rule Guidance

Dallas T. Kiedrowski, MNAA — Fri, 23 Aug 2024 12:30:47 +0000

County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach. The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...

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Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

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AMCs Billing Scheme, Hidden Profits & Deceptive Practices

Guest Author — Wed, 07 Feb 2024 13:30:29 +0000

Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace for appraisal orders. Appraisal Management Companies (AMC’s) do not pass on cost savings for reduced appraisal services to consumers. Instead, they keep the savings for themselves without disclosing the amount to the consumer or the appraiser. What should have been cost savings for the consumer are pocketed by the AMC in secret. This is considered a junk fee or unearned fee billing scheme under current law. Appraisers who participate in this system are in violation of The Management Rule of...

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Seller Filed a Racial Bias Complaint Against Me

Guest Author — Tue, 07 Nov 2023 13:30:08 +0000

So what’s caused the sudden loss of income? Could it be because of the racial bias complaint filed against me by an unhappy Seller… Fannie Mae accomplished what they set out to do in July 2011, when they initiated their Uniform Appraisal Dataset (UAD) and the Uniform Collateral Data Portal. The goal was to collect enough property data to effectively remove appraisers from the home buying and refinancing process. It all started with Dodd-Frank Act, a several hundred pages Act signed into law by then President Obama, sold to unsuspecting Americans as a protection from the corrupt business practices of...

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Dear Representative, FNMA Has Gone Rogue!

AppraisersBlogs — Mon, 27 Mar 2023 12:30:24 +0000

Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending purposes is nothing more than wanton recklessness that could have serious repercussions in the future. The truth of the matter is that appraisals are an essential part of any mortgage transaction and should not be taken lightly or eliminated without due consideration. Without them, there can be no assurance as to whether a homebuyer will get what they pay for or if lenders will make bad investments with their money. In short, waiving/eliminating property appraisal requirements puts everyone at risk...

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Look in the Mirror

Mark Skapinetz — Mon, 27 Feb 2023 13:30:14 +0000

The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is a powerful statement that can evoke a range of emotions and reactions from individuals, from contemplation to defensiveness. At its core, the phrase is a call to examine oneself honestly and objectively. It asks us to step back from our assumptions, biases, and preconceptions and consider our behavior, choices, and beliefs in a critical light. When we take a look in the mirror, we are forced to confront our flaws and shortcomings, but also to recognize our strengths and achievements....

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Fastapp AMC Alleged Violations of AIR

AppraisersBlogs — Wed, 01 Feb 2023 13:30:55 +0000

The following court documents in the case Naftali Horowitz v. [xxx], Fastapp AMC founder v. Fastapp AMC president, confirm what appraisers have been saying all along, that if you want high-volume AMC work, you have to lower your fees to 1980’s level, have 24 hour turn times, and, above all, be a number hitter. Horowitz, Fastapp founder, filed a lawsuit in New York court on January 31, 2022 against defendant to, among other things, remove the defendant as an officer and director of the Company because, when he brought her on as shareholder in 2020, he claimed that she made...

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AMCs Take a Sizable Cut of the Appraisal Fee

Mark Skapinetz — Wed, 05 Oct 2022 12:30:29 +0000

It still proves my point: Appraisal Management Companies take a sizable Cut of the appraisal fee… It was March 28th, 2018 that I wrote my very first blog post entitled “What’s not in your wallet?” where I went into great detail about how Appraisal Management Companies or AMCs get paid and how the consumer is not aware of the fact that the AMC is taking much of the fee while finding the cheapest and fastest appraiser. In that blog post, I gave many examples of the abuse appraisers and consumers are absorbing by these Appraisal Management Companies. How one borrower...

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What Is My Incentive?

Michael Ford — Tue, 20 Sep 2022 12:30:38 +0000

Why would I bother taking on the added risk of an inconvenient process? Where is my incentive again? As an appraiser, I have to ask (seriously) why should I care if the profession has a shortage of skilled appraisers? Logic dictates that If there is a shortage, then I will remain busy. Even if waivers (another ruse to eliminate appraisal work) increase, I’ll be busier with fewer appraisers. Especially with so many of them “trained” under PAVE or PAREA programs. If there is an adequate supply of appraisers, then users of appraisals will continue to seek cheaper alternatives from them...

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Violating Appraisal Independence Through Harassment, Intimidation & Coercion

Dave Towne — Wed, 15 Jun 2022 12:30:59 +0000

It shall be unlawful… to engage in any act or practice that violates appraisal independence… Appraisers, I have written the info below, which you may use if you desire to send to your clients and local real estate offices. It’s time for all appraisers to stand up to this kind of very adverse behavior, done by and promoted by many real estate brokers/agents across the US. I have been chastised multiple times by brokers, and in one instance that I know of, was excluded (by the lender who told me) from doing another assignment when I didn’t appraise a prior...

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Federal Agency in Charge of Appraisers

Guest Author — Mon, 23 May 2022 12:30:12 +0000

Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is now. ALL appraisers should be SWAMPING their state representatives with calls & emails in OPPOSITION to newly introduced H.R. Bill entitled: Fair Appraisal and Inequity Reform Act of 2022. DO IT NOW. **Remind them all that the job of a Professional Real Estate Appraiser is to PROTECT THE PUBLIC TRUST. That’s what we are in place for! With all of the ridiculous changes proposed with “PAREA”, we know exactly where this is headed. Appraisers coming out of their “PAREA” certification...

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The Biggest Snow Job of Your Life

Guest Author — Thu, 15 Oct 2020 12:30:00 +0000

Remember the saying “Pick two: fast, cheap or good. You can only have two of them?” Well you see, amcs got impatient and stopped reading after fast and cheap… The concept is simple enough, a fire wall between the loan production staff and the appraiser to avoid any possible pressure, coercion or influence. It sounded like a good idea to many; hence the HVCC legislation passed and was enacted. This was a period of trial and error for so many and before anyone found their way, along came Mr. Dodd and Mr. Frank to give their official stamp of approval...

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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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Fee Transparency, Pivotal Point for Appraisers

Isaac Peck — Wed, 23 Oct 2019 12:30:10 +0000

…appraisers may finally have a chance at making the goal of fee transparency a reality… Keep your eyes open, events are happening fast. Ever since the passage of the Home Valuation Code of Conduct (HVCC) in 2010 and the monumental rise of Appraisal Management Companies (AMCs), one of the main issues appraisers have pressed for is transparency for consumers in terms of the fee split between appraisers and AMCs. Specifically, how much of the actual “Appraisal Fee” being paid by the consumer goes to the licensed real estate professional and how much is withheld by the AMC “manager.” Now, over...

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Bridging The Gap

Michael Ford — Mon, 23 Apr 2018 12:30:57 +0000

I’m an appraiser. I look at all proposed financial reform legislation in terms of what it does for, or to appraisers. Not whether it was proposed by a red or a blue. Dear AppraisersBlogs readers and fellow appraisers; Anyone who has read my past posts is aware I happen to be a Republican Union Organizer. Usually it isn’t an issue because I try to remain non partisan in my posts and to avoid offensive partisan rhetoric, while promoting appraisers rights; the American Guild of Appraisers, and being critical of bad lending policy and bad appraisal practices. I have also attempted...

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Stop S.2155 in the Senate

VaCAP Board — Mon, 05 Mar 2018 13:30:53 +0000

Call to action to oppose Senate Bill 2155, also opposed by an overwhelming majority of Americans… Appraisers, We are placing an immediate nationwide call to action to oppose Senate Bill 2155 currently in the United States Senate. Senate Bill 2155 has a provision, (sec 103) which allows a bank to waive an appraisal in rural communities. This will be detrimental for homeowners and communities in rural areas. A loss of income will also occur for appraisers who cover rural counties. To see the text of S.2155, click here. The Independent Community Bank Association has been hard at work promoting this bill....

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