Tagged: FDIC

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 24

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

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

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

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 38

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

ACI / AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News

Low AMC Fees? FDIC Wants to Hear from Appraisers 24

Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

AMCs paying low fees, Appraisers and Regulation Z of TILA VaCAP recently learned of some encouraging news. The FDIC wants Regulation Z to be followed and will enforce it for appraisers. Here is what VaCAP received from an appraiser who reached out to the FDIC: I just had a call from an extremely pleasant lady named Susan Welch from the FDIC Consumer Response Center (1-800-378-9581). I had sent a note over regarding an AMC attempting to get me to sign a “Base Fee Letter” agreeing to a drop of my base fee for full appraisals to $325 from $400-500. She...

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

AMC staff appraiser positions and the lack of public protection and trust 1

Virginia Appraisers in the Spotlight Again

AMC staff appraisers are not independent If you have not already done so, please listen to the Voice of Appraisal with Phil Crawford. Once again, Phil has brought Virginia into the spot light. This is the third show Phil has talked about AMC staff appraiser positions and the lack of public protection and trust. Thank You Phil and Kevin! Listen to the show at the bottom of this article. Please attend and speak against AMCs hiring staff appraisers to complete the appraisal reports. By definition, an AMC and an appraiser have two very different functions. Even the National Association of...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / VaCAP

Independent Appraiser Takeover by AMCs 34

An AMC Takeover is Coming!

AMCs completing appraisal reports in direct competition with the independent appraiser As an appraiser, you have probably seen or heard that AMCs are hiring staff appraisers to complete appraisal assignments in local markets. What does this mean for independent fee appraisers? Here is some background information to consider. 54.1-2020 of the Code of Virginia states: An Appraisal Management Company is “a person or entity that (i) administers a network of independent contract appraisers, receives requests for appraisals from clients, and receives a fee paid by the client for the appraisals and (ii) enters into an agreement with one or more...

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

Comments Continue to be Invited - Appraisers Call to Action 6

Should the Government Accept Appraisers’ Complaints?

If you believe the government should be accepting complaints from appraisers regarding Appraiser Independence Issues, then please send your comments Please respond to the call to action below! The IACF was developed for use by those who wish to file a formal, written complaint that an entity subject to the jurisdiction of one or more Agencies, the Board, or the NCUA has failed to comply with the appraisal independence standards or USPAP. The IACF is designed to collect information necessary for one or both of the Agencies, the Board, or the NCUA to take further action on a complaint from...

Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / FDIC / The Federal Deposit Insurance Corp.

Big data is in real estate 13

Big Data is in Real Estate

The only thing Big Data can’t do is smell. I got a call from my credit card company. Now I have been traveling a lot lately on business. Apparently, someone got my number and charged $199.53 at WalMart on Monday. I was not in WalMart, but a couple a weeks ago I bought a new TV at Sam’s Club. No question about the Sam’s Club purchase. How did they know I did not go to WalMart? I am truly amazed. The reason – BIG DATA! The banks are amassing massive amounts of data on you, me, everyone. They know more...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CoreLogic Valuation Services

Second appraisal controversy - argument 11

Second Appraisal Controversy

On reading a recent post about agents telling their clients to just order a second appraisal when the values came in ‘low’, I’m reminded of an old saying that both my parents used to frequently address toward me, “People who live in glass houses, shouldn’t be throwing stones.” I had no idea what they were talking about since when growing up I’m CERTAIN that ALL of my criticisms were well founded and deserved by those they were directed to. Teachers, government officials, world politicians, teachers, general authority figures, friends, enemies, and did I mention teachers? Basically most of the entire...

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

FFIEC Requested Action on TRID - Imagecredit Flickr - Johannes Ahlmann 6

FFIEC Requested Action on TRID

The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...

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

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