No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...
I saw a posting by another appraiser on a Facebook page on February 5, 2019 that MCS Valuations, based in Lewisville, TX, is closing shop. They are an AMC, and provide BPO’s and other real estate related services. The appraiser posted a letter from the company. They will not be placing any more appraisal assignments, but are asking appraisers to finish any assigned reports already in the pipeline. What’s really striking about this closure is that in 2014, MCS Valuations bought ‘components’ of CoreLogic’s associated entities that CoreLogic no longer wanted in their business! February 5, 2019 This communication is to inform...
Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF. USPAP compliance is required for federally related transactions. USPAP comprises two parts:...
The industry is working of an appraisal simulator… The US House of Representatives Passed S 2155 today! Section 103 allows for waivers of appraisals by licensed appraisers in certain situations. See the bill here. Other News: Last week The National Association of Realtors held their Real Property Valuation Committee meeting. We have 2 VaCAP members on this committee. Here is a brief over view of the meeting from our representative in attendance. John Brenan with the Appraisal Qualifications Board (AQB) spoke at the meeting and gave an update on the roll back of licensing requirements that went into effect May 1st....
Community Banks want to bypass appraisals in rural area… Evaluations are the answer, right? There have been lots of discussions lately concerning property inspection waivers, waivers of appraisals in rural areas, and allowing appraisers to complete Evaluations outside of USPAP standards. Doesn’t this all sound familiar? It should, we have already lived it 30 some years ago, prior to FIRREA. Back then Savings and Loans had staff appraisers to complete appraisals. The appraisal was not completed by a licensed appraiser, because licensing to protect the public did not exist. Today Community Banks want to bypass appraisals in rural area. Their...
Three bills introduced concerning our profession… Fellow Appraisers, The 2018 Virginia General Assembly has begun and there are three bills that have been introduced concerning our profession. VaCAP is not behind any of these bills and we honestly do not know how they came about. We were truly blind-sided by them. We ask that you contact your representatives and offer your support, opposition and suggestions. It is also a good idea to contact the committee members that will be discussing and voting on each of these bills. We will continue to follow the bills and alert you when they appear...
Could Ocwen’s trouble mean more business for appraisers? Ocwen Financial is in trouble with 22 States and the Consumer Financial Protection Bureau. Some states have issued a Cease and Desist Order, others like South Dakota are telling it like it is: “Ocwen does not possess the competence, experience, character, or general fitness required to permit Ocwen to continue…” Could this mean more business for appraisers? Will these issues be found in other lenders? How will the Real Estate and mortgage market be impacted? Time will tell. In the meantime, read all about Ocwen’s trouble on HousingWire here. In Other News:...
An evaluation, when performed by an individual acting as an appraiser, is an appraisal… Recently, a document entitled, The Interagency Advisory on Use of Evaluations in Real Estate-Related Financial Transactions was released. Many in the lending and appraisal professions see this as a federal permission slip for evaluations to be completed by Illinois Certified Appraisers. The document reiterates what we already know about evaluations: Under the appraisal regulations, the following transaction types do not require an appraisal, but do require an evaluation: Transactions in which the “transaction value” (generally the loan amount) is $250,000 or less; Certain renewals, refinances, or other transactions involving...
Appraisers, I know everyone is busy right now, but this cannot wait. This may be the most important blog post affecting appraisers this year. I don’t think it is an exaggeration to say that if something is not done, it really COULD lead to the end of ALL residential appraisers for federally regulated transactions under $500,001. FFIEC under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), is considering raising the de minimis lending level from $250,000 to $500,000, because the local community banks are complaining that they cannot find enough appraisers in rural America to handle the volume! If...
Frankly this form is so screwed up! To First American Mortgage Solutions…(copy to appraisers around the US): Do you folks really understand what your PACE form report REALLY is?? It is not an Evaluation report. It is an actual appraisal, disguised very poorly as a so-called Evaluation. Here’s what I found in your form, after actually reading it: “This report is provided for the benefit of the named customer only and is not intended to be, nor shall it be deemed to be, an appraisal or any form of an appraisal.” OK, fine, not an appraisal. The main form page says...
