FTC seeking to punish LREAB for following federal regulatory mandates… BATON ROUGE, LA (May 31, 2017) – In an administrative complaint filed today by the Federal Trade Commission (FTC), it was alleged that the Louisiana Real Estate Appraisers Board (LREAB) had fixed the minimum price of residential real estate appraisals by enforcing the Board’s obligations under federal law to ensure that appraisers are paid customary and reasonable fees for their services. Bruce Unangst, Executive Director of the Louisiana Real Estate Appraisers Board (LREAB), said: “Respectfully, the FTC is just plain wrong. By issuing this legally faulty and factually incorrect complaint,...
FHFA raises conforming loan limits for mortgages acquired by Fannie Mae and Freddie Mac Appraisers, The announcement by Federal Housing Finance Agency (FHFA) on November 23, 2016 may affect your fee structure if your fees are higher for loans above the upper limit for home sale prices for a standard mortgage loan, so called conforming loan. When mortgage loans are for amounts higher than the conforming limit, the loans are termed “Jumbo” loans. This is not the same as basing appraisal fees on APPRAISED values. As a general statement, Jumbo loans are for homes with excessive characteristics – considered ‘complex’...
Impact of the Home Valuation Code of Conduct on Appraisal and Mortgage Outcomes During the housing crisis, it came to be recognized that inflated home mortgage appraisals were widespread during the subprime boom. The New York State Attorney General’s office investigated this issue with respect to one particular lender and Fannie Mae and Freddie Mac. The investigation resulted in an agreement between the Attorney General’s office, the government-sponsored enterprises (GSEs), and the Federal Housing Finance Agency (the GSEs’ federal regulator) in 2008, in which the GSEs agreed to adopt the Home Valuation Code of Conduct (HVCC). Using unique data sets...
We urge appraisers to review the PADS Model Current economic trends suggest your appraisal practice will not survive beyond 2015. Appraisers are running for the exits, with many moving into Ad Valorem, and some into cost estimating. Client accounts you thought were safe have been converted to ether and dispersed among a dark refinancing void. You’ve gone from completing six appraisals per week to camping by your email, in hopes of an AMC broadcast assignment appearing. Where you once had time to think about accepting the assignment, you now have less than 2 seconds to accept, because like you, ninety...
Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...
A common misconception of Fannie Mae’s Appraiser Independence Requirements (AIR) is that lenders are required to use third-party vendors or appraisal management companies (AMCs) to ensure compliance. In fact, lenders are not required to use an AMC or any other third-party vendor to order appraisals…
Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule that would implement minimum requirements for state registration and supervision of appraisal management companies (AMCs). An AMC is an entity that serves as an intermediary between appraisers and lenders and provides appraisal management services. In accordance with section 1124 of Title XI of the Financial Institution Reform, Recovery, and Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the minimum requirements in the proposed rule would apply to states that...
Increasing FHFA oversight of UCDP use… Fannie Mae and Freddie Mac failed to fully analyze data from the Uniform Collateral Data Portal and continue to take unnecessary risks when purchasing and guaranteeing single-family residential mortgages, according to a report from the Federal Housing Finance Agency’s Office of the Inspector General, Mortgage Daily reported Feb. 6. The report indicated that the two government-sponsored enterprises are not taking full advantage of appraisal data collected through the UCDP that the Federal Housing Finance Agency directed the GSEs to use in 2010 in an effort to improve loan quality and risk management. Mortgage Daily...
Outright Fake E&O For many appraisers and also some AMCs (appraisal management companies), the only reason they purchase professional liability insurance (E&O) is because a client requires them to show coverage in order to receive work. The fact that some appraisers and AMCs only look at insurance as an “E&O ticket” leads to some unfortunate examples of fraud, which appraisers, firms, AMCs and clients should be aware of. Before I get to the fakery, however, I’ll explain that our purpose in providing E&O, and also the reason that most of our insureds purchase it, is because E&O first serves the insured by providing...
Navigators Sues More Appraisers to Deny Coverage under “Regulatory Claims” Exclusion Last Thursday, November 14, Navigators Insurance Company sued two more appraisers to enforce “regulatory claims” exclusions in the E&O policies they purchased. These appraisers are in Nevada. Like the appraiser sued by Navigators in Florida on November 6, the Nevada appraisers are being sued by the FDIC for professional negligence in cases filed about a year ago. The objective of Navigators’ lawsuits is to seek court confirmation of Navigators’ legal position that there is no coverage under Navigators’ policy for damages awarded against the appraisers to the FDIC, which is demanding about $500,000...
