Dodd Frank Law - Appraisers Blogs

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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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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A New ‘Standard’ for ROV Requests

Dave Towne — Tue, 21 Dec 2021 13:30:55 +0000

Since beginning using this Standard, I have had ZERO ROV requests. Appraisers, the latest ‘buzzword’ around appraising is Standard. We’ve got to have a Standard for measuring a subject dwelling, even though the comparable GLA reported figure may have been measured far differently from the new soon-to-be mandated Standard. Appraisers have no way of controlling the apples to oranges dissimilarities. But I digress… According to the Dodd-Frank law, and the HVCC before it, clients are allowed to challenge the appraiser’s value opinion by submitting what is termed in the law “appropriate” sales to be further reviewed, with the expectation that...

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A Little Push Can’t Hurt Right? Wrong!!

Mark Skapinetz — Fri, 29 Mar 2019 12:30:57 +0000

…forget the risky position foisted on the consumer by the loan officer… Well, here we go again. In my previous blog posts titled “Round and Round” and “Pressure My Story”, I spoke to examples of how lenders and/or AMCs have been pushing and pressuring appraisers to hit certain values on transactions. If an appraiser did not hit these numbers, or make changes to make the transaction work in the lender’s favor, the appraiser would be threatened with non-payment, removal from appraiser panels, and/or blacklisted. If you haven’t read those blog posts, feel free to go back and have a look....

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AGA Objects De Minimis Increase Proposal

Michael Ford — Thu, 10 Jan 2019 13:30:09 +0000

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

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Baby or Bath Water? And Is it Time to Take Back USPAP?

Michael Ford — Fri, 24 Feb 2017 13:30:02 +0000

About half of AICPA members don’t believe in USPAP… When I first heard that “they” were trying to do away with the Appraisal Practices Board (APB) of the Appraisal Foundation (TAF), I tried to keep an open mind. I also wondered who “they” are. Did the Appraisal Institute (AI) finally get a sympathetic ear in Congress? Was it preemptive action by the Board of Trustees in anticipation of budget cuts by the new administration? By the way, what does the APB do? I certainly had it wrong. I thought they helped develop the Advisory Opinions (AOs)! To be candid the...

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AI’s Effort to Eliminate the ASC!

Michael Ford — Wed, 22 Feb 2017 13:30:40 +0000

Refocused effort to eliminate the ASC… Why? It’s now much more than rumor. There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself! Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too! It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to...

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Life After Dodd-Frank

IDFPR Board — Wed, 25 Jan 2017 13:30:25 +0000

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

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VaCap Speaking out Regarding C&R Fees

VaCAP Board — Fri, 13 Nov 2015 13:30:20 +0000

CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs. AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession. In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement. First, the Feds have made it very clear that lenders...

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Evolution of C&R fees – Alter Your Thinking

Dave Towne — Mon, 27 Apr 2015 12:30:29 +0000

Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...

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Appraiser Background Check Requirements

Dave Towne — Mon, 30 Mar 2015 12:30:01 +0000

The info below from AI’s Appraiser News OnLine is about the action taken by the AQB at their recent meeting in Seattle, WA, which I was unable to attend. It’s still unclear if “existing license holders” must undergo a background check at the time of their license renewal. Apparently that’s determined by individual states. And it’s still difficult to get all the multiple clients appraisers deal with, to accept “one” background check performed in a state or by a separate organization. So appraisers are sometimes faced with having to spend money to provide different background checks to individual clients. Frankly,...

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AMCs to Pay Appraisers C&R Fees

VaCAP Board — Fri, 30 Jan 2015 13:30:33 +0000

Call to Action in Support of Virginia Senate Bill Requiring AMCs to Pay Appraisers C&R Fees Appraiser Colleagues, Finally, you have an opportunity to get what you have been screaming for: customary and reasonable fees for your work. On January 23, 2015, Senator Martin offered Senate Bill NO. 1445, requiring appraisal management companies to pay appraisers customary and reasonable fees. The bill mirrors the language in Dodd-Frank. A copy of SB 1445 as introduced is attached. Please contact your legislative representatives in support of this important legislation. VAR’s support will be important to the success of this bill. Please include VAR...

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CU Process Will Improve Appraisals? A Pipedream or Reality?

Dave Towne — Mon, 05 Jan 2015 13:30:32 +0000

Fannie Mae Claims the CU Process Will “Improve Appraisals.” A Pipedream or Reality? Appraisers, A few days ago, I watched the FNMA eLearning webinar “Introduction to CU” video showing how their new Collateral Underwriter will be implemented, starting on Jan. 26, 2015, applying to 1004 and 1073 Reports (initially). You really should watch this also! CU applies to FANNIE MAE only; FreddieMac, VA, FHA, USDA are not involved at this time. Click this link, and you’ll find the link to the video ½ way down on the left. I captured a few screen shots of their presentation to help explain...

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Working for an AMC? How Exciting!

Hamp Thomas — Fri, 17 Oct 2014 12:30:30 +0000

Can You Tell I’m Excited about working for an Appraisal Management Company? Today I received a notice telling me my best customer was changing over to an AMC for all their appraisal ordering. I have worked for this company for many years and have always enjoyed a great relationship. Today that ended. I can longer talk to any person at the bank. In my application to continue working for this company I have worked with for so long, I have to provide sample reports, a resume, three business references, license info, info about CE classes I have taken. I have...

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Residential C&R Fees Study in Virginia

VaCAP Board — Wed, 15 Oct 2014 12:30:51 +0000

Virginia Study on Customary & Reasonable Fees for Residential Appraisals BLACKSBURG, Va., Oct. 7, 2014 – Virginia Tech researchers and students conducted a survey of Virginia residential real estate appraisers to analyze the patterns of fees earned in 2013. Prior to the release of this report, no data existed that defined “customary and reasonable” residential real estate appraisal fees in Virginia. This report is the third report of its type to be conducted in the United States, and the first in Virginia. The research was conducted in response to recent amendments to the Truth in Lending Act modified by the...

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Real Estate Appraiser Lifestyle

Dustin Harris — Thu, 10 Jul 2014 12:30:00 +0000

I cannot help but wonder why more appraisers do not jump ship and find another career if it is so bad out there. Now, I am not without compassion. I know it is not as easy as trading in your clipboard for a spatula. Changing jobs is a difficult process and does not happen without much consternation and heartache. However, I tend to think that so many of us are sticking it out because...

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You Are Being Robbed Blind

Guest Author — Fri, 20 Jun 2014 12:30:03 +0000

You Are Being Robbed Blind (24 Hour Membership Deadline) AMCs are concealing their profits within YOUR appraisal fee, and using coercion to drive down YOUR income as far as they can. This government-permitted process allows them to rob you blind while building their appraiser-squeezing power even stronger. NOW is the time to take a stand to fix this broken industry and the career you have spent a lifetime building. The Appraiser Prosperity Coalition was formed to fight for the legislative and regulatory changes needed to save this devastated industry. If you are willing to join us today, we can defeat the...

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Agencies AMC Rules Lack Guidance

AppraisersBlogs — Wed, 18 Jun 2014 12:30:12 +0000

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

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Announcing VT Customary and Reasonable Fee Survey Release

VaCAP Board — Tue, 13 May 2014 14:29:27 +0000

Dear Appraiser Colleagues, Awhile back, you responded to a request from VaCAP to supply your e-mail address to participate in an upcoming Customary and Reasonable Fee Survey to be conducted by the Virginia Center for Housing Research and the Virginia Tech Program in Real Estate. This communication is to notify you of the survey’s eminent release. Please look for it to be sent to you via e-mail in the next couple of days. Your participation in the survey is vital to the success of this endeavor. Please take the few minutes necessary to complete the survey; it should only take...

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