Tagged: FIRREA

Appraisal Regulations - Life After Dodd-Frank ~ copyright AppraisersBlogs 5

Life After Dodd-Frank

Do the agencies’ appraisal regulations apply to FHA, VA… Republican control of Washington DC will mean one of two things: A scaling back of Dodd-Frank, or The elimination of Dodd-Frank Like it or not, one of these two scenarios will play itself out in 2017 or 2018. What about AMCs? The AMC Final Rule was deemed that…the registration and supervision of AMCs is voluntary, and that a State may elect not to establish such a program for any reason, including if its resources do not support such a program. Will the states walk away from AMC regulation? Perhaps not all, but definitely some states will either bypass the...

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

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

STOP the Idiotic Constant Parsing Changes in All Areas of USPAP 14

It’s Time to STOP the Foolishness

STOP the constant parsing changes in all areas of USPAP I encourage ALL appraisers in the DC Metro area to attend the upcoming ASB Public Meeting on October 21, 2016. In a nut shell, my strong belief is that they need to STOP the constant parsing changes in all areas of USPAP. NOT ONE of the proposed changes is a necessary change. NOT ONE! No wonder state regulators no longer comprehend USPAP! If they need the extra money that selling new versions of USPAP produces, then just CHARGE US DIRECTLY! The purpose of FIRREA was to preserve the public’s trust...

AGA / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / ASB

Serfs Are Starting to Get Upset 10

Serfs Are Starting to Get Upset

The serfs are PISSED! Apologies. America was not founded by people that ‘went along to get along’, or that were willing to accept economic or political serfdom. Though they did so until a critical mass of frustration was reached. It is human nature to seek and then protect the benefits of privilege. To some extent this is a positive attribute. It’s the foundation of Capitalism. It is only when dishonesty and manipulation of laws becomes prevalent that the system is at risk, and not operating properly. We had dueling to keep honorable people honorable two hundred years ago. That was...

AGA / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal News / Appraisers News / ASA

AVMs can Never replace Appraisals 34

AVMs Can NEVER Replace Appraisals

AVMs Can NEVER Replace Appraisals & why FNMAs vaunted CU AVM is flawed! Yesterday (March 15, 2016), an appraiser called me to discuss a complex assignment he had. One of his comparable sales was reported in MLS as having sold for $3,469, 898. It was in range with his other comparable sales for his subject property. It was the most similar comparable property. When he went to verify the sale price with our Los Angeles, California subscription-equivalent to “public records” he discovered a shocking discrepancy he couldn’t explain. RealQuest (CoreLogic) showed the full value sale price as $17,665,455! So what...

1004MC / AGA / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News

Experience, Education Criteria Input Request & AGA Open Letter 18

AGA Open Letter Regarding Changes to the Criteria

Request for appraiser input on current and future educational / experience requirements… The AGA sent the below letter to the AQB in response to their outreach asking for comments. Please write them and tell them YOUR views. If you agree with what we have said, then just copy it and add your name to it saying “we agree”. Or don’t copy it, and just say “We agree with the AGA letter”. If there are any significant parts you disagree with, then please ‘except’ those. If you have additional thoughts or suggestions for them (civil ones), feel free to add them....

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

AMC's “My Way or the Highway” Attitude 47

AMC’s “My Way or the Highway” Attitude

Apparent appraiser abuse by AMC’s… As Chairman of the American Guild of Appraisers (AGA) National Appraiser Peer Review Committee, I have had the opportunity to see and hear directly about many cases involving alleged, as well as apparent appraiser abuse by AMC’s. These cases ranged geographically from California, Arizona, Michigan, Illinois, Florida, North Carolina, Louisiana, New Jersey, Virginia, New York, Maryland, and District of Columbia. As a QC consultant to a smaller appraiser owned AMC, I have also seen low fee spreadsheets from a variety of lenders that had 90% listed at the SAME APPRAISER fees: $495.00 (which INCLUDED the AMC...

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

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

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

ASA Letter opposing Bill A3781 2

ASA Letter Opposing Bill A3781

Letter from ASA Opposing Bill A3781 Abolishing the NJ State Appraisal Board and Transferring Control to the Real Estate Commission Assemblyman Giblin: The American Society of Appraisers (ASA), the largest multidisciplinary professional appraisal organization in the United States, is writing to express strong opposition to Assembly Bill 3781, which would abolish the New Jersey State Real Estate Appraiser Board and transfer the regulatory oversight of appraisers to the State Real Estate Commission. This bill would weaken the overall regulatory scheme applied to real estate transactions and its myriad parties at a time when new federal and federally-mandated state regulations are...

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

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline 1

ASA, NAIFA File Comments Regarding Appraisal Complaint Hotline

The establishment of an appraisal complaint hotline… The American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) appreciate the opportunity to jointly comment on the Paperwork Reduction Act implications of the establishment of the Appraisal Complaint Hotline system mandated by section 1473 of Dodd-Frank. Although we understand that the public will have an opportunity to comment on the appraisal complaint form itself when it is proposed (described as “the Interagency Appraisal Complaint Form”), we believe the agencies’ October 22nd Federal Register request for comment provides our organizations (and other stakeholders) with an important opportunity to...

American Society of Appraisers / Appraisal / Appraisal News / Appraisal Organizations / Appraisal Subcommittee / Appraisers News

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