Tagged: Dodd Frank

Financial Reform Legislation in Terms of What it Does For or To Appraisers 12

Bridging The Gap

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...

AGA / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / CFPB

Stop Senate Bill 2155 in the Senate, Fake Claim of an Appraisers Shortage 49

Stop S.2155 in the Senate

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....

Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / Customary & Reasonable Fees / Dodd-Frank Act / C&R Fees

Price Fixing? Why is the FTC Involved at All? FTC vs Louisiana Hearing 32

Price Fixing? Why is the FTC Involved at All?

FTC "Price Fixing" Allegations Hearing Update On Thursday, Feb 22, 2018 there were oral arguments presented in the Federal Trade Commission building at 2 pm. The meeting adjourned just before 3:30 pm. There were 55 to 65 people in attendance, which we were told is an extraordinarily larger crowd than typical. This is a very unique case. On the FTC side there were two lawyers – one male, one female. On the Louisiana side there were four males at the head counsel table and three or four other attorneys. I have never attended one of these hearings, so I really did...

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

Evaluation NOT required to Meet USPAP - AGA Views on Legislative Bills 17

The Devil is Always in The Details

An evaluation is NOT required to meet USPAP requirements… I went over the bills VaCAP requested action on (see VaCAP Legislative Call to Action) and wanted to share my views as it appears they were interested in individual views. HB 1453 Real estate appraisers; changes definition of evaluations. Introduced by: R. Lee Ware SUMMARY AS INTRODUCED: Real estate appraisers; evaluations. Changes the definition of "evaluation" from an analysis, opinion, or conclusion relating to the nature, quality, value, or utility of specified interests in, or aspects of, identified real property to an opinion of the market value of real property or real...

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

Reconsideration of Value Requests & Undue Influence on Appraisers 21

Reconsideration of Value Requests

Open invitation for spurious reconsideration requests… No thank you. I just checked your website and glanced at your “clients” tab, Reconsideration request form. It pretty well negates all the puffed up hyperbole in your email invitation. It is people like you that are the problem, not solutions. Do you think a one of two items drop down menu is an adequate reason for asking an appraiser to reconsider their value? Do you not see a need to request a full and thorough explanation as to why your clients might be asking for a reconsideration? At a minimum didn’t you feel...

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

Valuation Partners & Schizophrenic AMCs vs. Appraisal Professionalism 23

FTC & REVP vs LREAB Bombshell

Like many other appraisers I received a copy of paperwork filed in conjunction with the Louisiana Real Estate Appraisers Board / FTC and Real Estate Valuation Partners (REVP) aka Valuation Partners. (Thank you VaCAP!) To me it’s a bombshell, but before I go into the story of who did what to whom, and for how much let’s start off by asking all readers to click this link to see who the players are. Even if you read the article elsewhere please read the following link. Got it? Great. Just so we are clear, one of the Chief players appears to...

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

Blast AMCs Emails Do Not Meet the Spirit of The Law 16

What Goes On Behind The Scenes…

This year it appears many AMCs have turned to blast requests of fee and turn time. We get them constantly and simply delete them. Last week we received a blast email from an AMC that sends out blast requests for bids. We have never worked with Appraisal Nation before and don’t know how we ended up on their panel. In their rush shopping for the cheapest and fastest appraisers, they forgot to BCC the appraisers they blasted. It appears that this AMC is not only incapable of maintaining quality control and assuring competency for specific assignments but by disclosing appraisers’...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

Request for Appraisal Waivers If Granted Will Erode Public Trust 68

Appraisal Waivers vs. Public Trust

If the ASC grants the request for appraisal waivers, the precedent will have been set for other banks to follow… TriStar Bank has requested appraisal waivers for the entire year of 2018. According to the bank, they are having difficulty getting appraisals in the Nashville area and there is only one Certified General Appraiser in the the locality in which they are headquartered. Below is an excerpt form their letter to the ASC. They offer options in lieu of appraisals: Obtain an estimated value from a Realtor, selected from a small group of trusted Realtors who are not involved in...

Appraisal / Appraisal News / Appraisal Organizations / Appraisal Subcommittee / Appraisers News / ASC

Increasing use of AMS to replace AMCs 15

Increasing use of AMS to replace AMCs

AMS on fast track to replace AMCs… Well, it looks like the detritus of HVCC has finally come full circle. AMS (services vs companies) are on the fast track to replace AMCs. AMCs that foster their use haven’t realized that yet. They have given the lenders the tools needed to avoid costly appraisal management oversight departments while at the same time giving them the ability to use only those appraisers willing to make the deals work. They mistakenly believe that by delegating to an AMS or AMC they have met their due diligence requirements.Quality control? Sure. Just ignore the FNMA...

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

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What Can You Do When AMC Does Not Pay?

What happens when an AMC does not pay or closes its doors & should funds collected for appraisals be kept in escrow? 54.1-2021.1 of the Code of Virginia requires AMCs to post a $100,000 bond or letter of credit. Appraisers may be able to file a claim against the bond or letter of credit and receive funds if they have not been paid. Directly from the statute: “§ 54.1-2021.1. Appraisal management companies; license required; posting of bond or letter of credit. In addition to the filing fee, each applicant for licensure shall post either a bond or a letter of credit...

AMC / Appraisal / Appraisal Management Companies / Appraisal Organizations / Fannie Mae - Freddie Mac / VaCAP

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