Tagged: Dodd Frank

AGA Statement to House Financial Services Committee Hearing 3

AGA Statement to House Financial Services Committee Hearing

The American Guild of Appraisers Statement to House Financial Services Committee Hearing Madam Chairman and Members of the Committee, on behalf of the American Guild of Appraisers/OPEIU Guild 44 (AGA) thank you for the opportunity to submit this statement in connection with today’s hearing on the real estate appraisal profession and the regulation of appraisers and appraisal practice. The AGA is a membership organization that seeks to represent the interests of appraisers related to federal and state regulation of appraisal practice and to industry practices that impact on appraisers and appraisals. In addition, working closely with other like-minded organizations including...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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TAF Response RE Gag Rule

TAF Response to Columbia Institute eVIP Appraisal News April 6, 2012, Mr. George Harrison, The Columbia Institute Dear Mr. Harrison: This is regarding an item that appeared in the “Ask George” column in the April 2 edition of eVIP Appraisal News. The question and answer relates to Appraisal Sponsors of The Appraisal Foundation apparently being under some type of constraint regarding freedom of expression. You have made a similar claim in a previous column and we thought that it was time to correct the record. You state that “The Appraisal Foundation has a restriction clause – gag rule – in its...

AI / American Society of Appraisers / APB / Appraisal / Appraisal Institute / Appraisal News

Top to Bottom Complaint Primer 0

Top to Bottom: Complaint Primer

“Why don’t you write about the complaint process from start to finish?” Howard Richter, MAI of IACREA made a great suggestion for an article. “Why don’t you write about the complaint process from start to finish?” Okay, Howard. Let’s do it! Whether complaints come from homeowners, lenders, AMCs, other government entities, they all find their way to my desk via Complaint Intake. The two-page complaint form is on-line and was designed to make it easy for the complainant and for the Department to get to the heart of the problem. Complaints come in all shapes and sizes. Some are vague...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

Proposed Amendments to the Sentencing Guidelines in Mortgage Fraud Cases 1

Sentencing Guidelines Proposal

Proposed Amendments to the Sentencing Guidelines Speaking at a March 14 hearing in Washington, D.C., the Appraisal Institute urged a federal judicial agency to require the use of real estate appraisals when calculating loss in mortgage fraud cases. In prepared written testimony, Appraisal Institute President Sara W. Stephens, MAI, told the U.S. Sentencing Commission, “We believe the Commission should adopt a special rule for determining the fair market value of real property if the mortgaged property has not been disposed of by the time of the sentencing. However, this rule should require use of real estate appraisals prepared by qualified...

AI / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal News / Appraisal Organizations

American Guild of Appraisers Petitions Fed 0

Fed Petitioned by American Guild of Appraisers

American Guild of Appraisers Petitions Fed and Consumer Financial Protection Bureau to Overturn Regulation that Threatens Viability of Professional Appraisal Practice WASHINGTON, Feb. 23, 2012 /PRNewswire-USNewswire/ — The American Guild of Appraisers (AGA), a national organization of real estate appraisers that is an affiliate of the AFL-CIO’s Office and Professional Employees International Union (OPEIU), has petitioned the Federal Reserve Board (“Fed”) and the Consumer Financial Protection Bureau to overturn a regulation adopted by the Fed that is contrary to the Dodd Frank Financial Reform law, threatens the viability of professional appraisal practice and undermines the legitimacy of real estate appraisals...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

AMC’s Filing Complaints Against Appraisers 1

AMC’s Filing Complaints Against Appraisers

AMC’s are sending in complaints on appraisers… From ICAP – Illinois Coalition of Appraisal Professionals “Good afternoon ICAP’ers, I am writing to our residential members regarding a growing problem that ICAP is concerned with regarding lenders and AMC’s filing complaints against appraisers. THE SETUP: You receive a call from a lender or an AMC who wants to talk to you about an appraisal assignment you recently completed for them. The call usually comes from the QC Department at the post closing stage of the loan. They start questioning you on your line item adjustments. All the comparables are on smaller...

ACOW / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers 1

American Guild of Appraisers Files Request RE C&R Fees

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers WASHINGTON, Jan. 23, 2012 /PRNewswire-USNewswire/ On behalf of the American Guild of Appraisers, today the law firm Garvey Schubert Barer filed a request with the Federal Reserve Board under the Freedom of Information Act seeking a wide variety of documents related to the regulations on customary and reasonable compensation of fee appraisers that were issued by the Board in October 2011. In announcing this action, Guild President Peter Vidi said, “It is clear that appraisal management companies...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 2

Appraisal Institute Seeks Separation of Appraisal and AMC Fees

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

AI / AMC / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal Management Companies

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GAO Report on ASC Hits the Street

On January 18, 2012, the US Government Accountability Office (GAO) released their report on real estate appraisals “Appraisal Subcommittee Needs to Improve Monitoring Procedures” as required per Dodd-Frank. GAO was tasked with 1) determining how the Appraisal Subcommittee (ASC) is carrying out its Title XI responsibilities, 2) ASC’s plans to implement Dodd-Frank provisions, and 3) regulatory dollar thresholds for determining when an appraisal is required. GAO reports that one of the challenges faced by ASC is in the area of resources and planning. GAO cites the creation of a national hotline as one example of a Dodd-Frank requirement that could...

Appraisal / Appraisal News / Appraisal Subcommittee / Appraisers News / ASC / Dodd-Frank Act / C&R Fees

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 0

CFPB Appraisal Fees

ASA has repeatedly stated its belief that the Fed’s interpretation and the massive loophole it created ran contrary to the plain language and clear intent of Dodd-Frank. CFPB Reissues Interim Final Rule On Valuation Independence, Eliminates Federal Reserve Commentary Permitting AMCs To Include Their Own Payments To Appraisers To Comply With Dodd-Frank’s Customary and Reasonable Fee Requirement. On December 22, the Consumer Financial Protection Bureau (CFPB) released an Interim Final Rule dealing with the valuation independence requirements imposed by the Dodd-Frank Act, including the law’s “customary and reasonable” fee mandate. The CFPB’s rule was republished to reflect the transfer of...

AMC / American Society of Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News

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