Tagged: Dodd Frank

Appraiser Independence Appraisal Independence 4

A Journal Piece of Appraiser Independence

A Journal Piece of Appraiser Independence (Part 1): Where Do We Go From Here? Buyer Beware! Where is the Value? (PART 1) In the years of 2007/2008, the ideologue of, “Appraiser Independence” had become popular for the real estate market’s economic agents and the processes it relies on to function properly. The idea gained respect, due to the perseverance of Real Estate Appraisers carrying out their Independence, during the decade of 2000-2010. The Home Valuation Code of Conduct (HVCC) was introduced according to prevailing design and initiative:  the advancement of a market in need for an inspired and renewed sense of...

In response to appraisers under attack 2

In Response to “Appraisers Under Attack”

In response to Frank Garay and Brian Steven’s commentary (see video below), on the lawsuit against TriMavin AMC over alleged appraisal independence violations, an anonymous commentator posted the following: There are a number of posters here who need to re-take their CE classes including the moderators. Here are the reasons the entire industry is severely broken. I mean from the Realtor to the Appraiser to the Mortgage Lender. First of all HVCC sunset folks – back in 2010. It was replaced with AIR (Appraiser Independence Regulations) and the Dodd Frank Act. Cannot tell you how irritating it is to me...

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...

Appraisal Exemptions Proposed Rule 1

Proposed Rule on HPML Appraisal Exemptions

Appraisal Exemptions: Agencies Issue Proposed Rule to Exempt Subset of Higher-Priced Mortgage Loans from Appraisal Requirements WASHINGTON— Six federal financial regulatory agencies today issued a proposed rule that would create exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans. The proposed exemptions are intended to save borrowers time and money and to promote the safety and soundness of creditors. The appraisal requirements for higher-priced mortgages were imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Under the Dodd-Frank Act, mortgage loans are considered to be higher-priced if they are secured by a consumer’s...

ES Appraisal Settlement with Chase 0

ES Appraisal Settlement with Chase

It has come to my attention that the attached settlement is being proposed to the BR Trustee in the ES Appraisal case and thought that it was important that the information be passed along to whomever might need it since many of our members have been affected. Please forward to whomever you believe might be owed fees in this case. I would recommend that anyone do their own research on this as I am only passing along information that was given to me third hand. It is the belief of others that this agreement will forgo millions of dollars in...

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REALTOR® & Appraiser Interaction Under Dodd-Frank

A common complaint among REALTORS® in virtually all of Michigan is that many residential deals are failing because the home will not appraise at a value that permits the buyers to finance the purchase and close on the home. Many REALTORS® take the position that many of these properties do not appraise because the appraiser is not “geographically competent.” In other words, the appraiser is from out-of-town, unacquainted with the area in which the appraised property is located; thus, fails to learn or uncover various factors that would substantially change the valuation of the property. The question is then posed...

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...

CoesterVMS Flat Fee Appraisal Structure Controversy 3

CoesterVMS Flat Fee Appraisal Structure Controversy

Lately, there has been some controversy surrounding the announcement of CoesterVMS implementation of a flat fee appraisal structure which went into effect on January 1. The announcement appeared on CoesterVMS Blog on January 7: CoesterVMS, a nationwide appraisal management company, has implemented the appraisal industry’s first ever flat fee model for residential appraisals. Under the flat fee model, which took effect on January 1, 2013, all conventional appraisals for mortgage lenders are priced at $450 while FHA appraisals are $475*. Customarily, appraisal management companies utilize a tiered fee structure, whereby prices are determined based on the property type or the...

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline 1

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline

The establishment of an appraisal complaint hotline… The American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) appreciate the opportunity to jointly comment on the Paperwork Reduction Act implications of the establishment of the Appraisal Complaint Hotline system mandated by section 1473 of Dodd-Frank. Although we understand that the public will have an opportunity to comment on the appraisal complaint form itself when it is proposed (described as “the Interagency Appraisal Complaint Form”), we believe the agencies’ October 22nd Federal Register request for comment provides our organizations (and other stakeholders) with an important opportunity to...

Appraisal USPAP Definition 0

Is That an Appraisal? USPAP Definition

Why Isn’t that an Appraisal? APPRAISAL: (noun) the act or process of developing an opinion of value; an opinion of value. (adjective) of or pertaining to appraising and related functions such as appraisal practice or appraisal services. Comment: An appraisal must be numerically expressed as a specific amount, as a range of numbers, or as a relationship (e.g., not more than, not less than) to a previous value opinion or numerical benchmark (e.g., assessed value, collateral value). In general terms the USPAP definition is elegant in its simplicity. We all understand what it is that appraisers provide. You provide opinions...

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