Tagged: hybrid appraisal

Existing Regulatory Burden on Appraisal, a Proven Failure- System Reform 6

Appraisal Reform or System Reform

It is my hope that the Subcommittee on Housing, Community Development and Insurance consider long-term impact. The existing regulatory burden, a proven failure, may insure a repeat of the past. The body of a letter to the U.S. House Committee on Financial Services about systems reform. Appraisal reform or Appraisal industry reform? It is critical to understand that ‘appraisal’ does not equal ‘valuation’, or risk analysis, or anything else.  It is a precise definition of a nebulous product. The current U.S. House Committee on Financial Services is asking the question: “What’s Your Home Worth? A Review of the Appraisal Industry.” I believe it is...

Proposed Hybrid Meeeting - Overwhelming Majority Were Against Hybrids 5

Overwhelming Majority Are Against Hybrids

The next Virginia Real Estate Appraisal Board Meeting will be held on July 30th, 2019 @ 10:00 AM. This meeting will be a historic meeting as the board will be discussing the proposed hybrid appraisal guidance document and the corresponding 153 public comments. Also on the agenda, CoesterVMS is listed under the disciplinary cases! Why is this meeting so important? First, the 153 comments is the second highest amount of comments that have been made on any guidance document in the past year. The highest amount of comments on any proposed guidance document was by the Board of Health Professions in which 727...

Bill Requires AMC to Disclose their Fee and Fee Paid to the Appraiser 12

Full Transparency in Fee Disclosure

Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the appraiser by the AMC… HB 3619 has been referred to the House Financial Services Committee. VaCAP has learned over the weekend that HB 3619 has been introduced in the US House of Representatives. HB 3619, short titled “Appraisal Reform Act of 2019” amends the Financial Institutions Reform, Recovery and Enforcement Act. The main change to  FIRREA deals with appraisal management company and appraiser trainee registries and the addition of a member of the Veterans Affairs on the Appraisal Subcommittee. The bill also modifies Section 2603,...

No Shortage Exists - Bankers Data Proves No Appraisal Shortage Exists 9

No Shortage Exists

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...

Take a Stand Against Actions Contributing to the Next Housing Crash 11

What Will It Take?

What is it going to take for every appraiser to comment on Town Hall concerning the proposed Guidance Document on hybrid appraisals? Even if you have no intentions of ever completing a hybrid appraisal, it is important for you to place a comment on Town Hall concerning the document and these questionable products. If appraisers are not willing to step up and take a stand against actions that are contributing to the next housing crash, who will? If you have seen any of the samples floating around on the blogs and forums, you realize very quickly, these products are not credible...

Clear Capital Admitting Hybrid Inspectors Are Offering Appraisal Opinions 34

Hybrid Inspectors Offering Appraisal Opinions

Clear Capital admission: This is an admission that inspector were previously offering appraisal opinions re Q&C. There remain many other areas in hybrids that also are appraisal opinion being provided by non appraisers. I have written many blog posts here, mainly for the consumer to read and understand what is actually happening in the world of Real Estate Valuations. My blogs range from being overcharged for appraisals so the middle man (the appraisal management company or AMC) can make money, lenders still pressuring appraisers to hit a value, and now having untrained and unlicensed people perform inspections (see my last...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. https://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Special Interests Killing Consumer Property Value Protection 13

Killing Consumer Property Value Protection

Before the ink was dry on FIRREA 1989, special interests were snipping away at it. Originally proposed field review requirements in FIRREA drafts for 1 in 10 appraisals would have made the Great Recession (TARP) impossible. Now those same interests are stripping away at the last vestiges of consumer and taxpayer property value protection. The formal appraisal. The MINIMUM level of protection that should be insisted upon. Dear Ms Kahng: My name is Mike Ford. I am Vice President – Special Projects; & Chairman of the American Guild of Appraisers National Appraiser Peer Review Committee; AGA#44, OPEIU, AFL-CIO. I am...

Bifurcated Appraisals, a Controversial Topic - Call to Action! 5

Bifurcated Appraisals, a Controversial Topic

As most of you know, hybrid or bifurcated appraisals are a very controversial topic currently. Virginia statutes and regulations have language which gives many of us pause on the compliance of hybrid appraisals as they are being presented in the industry. The Board has published a proposed guidance document in the hopes to clarify the language in our laws. Unfortunately, the proposed guidance document falls short of providing any meaningful guidance or clarification. Per Virginia statute, the document has been published on Virginia Legislative Town Hall for public comments. At the end of the comment period, it is our understanding...

Why Not Qualified Appraisers Instead of Cheap Appraiser Imposters? 29

Appraiser Imposters!

AMC sends a “non-appraiser” to photograph, measure, sketch, and observe a property, it’s quality, condition, and surroundings instead of using a qualified appraiser… I’m not an Appraiser, You just think I’m one Ever see the AT&T commercial where the surgeon walks in and he says “I Just got reinstated, Nervous? That’s ok so am I”. If not see here: https://youtu.be/1YT3erQZoq4   Or the late 1986 commercial with Peter Bergman that states I’m not really a doctor but I play one on TV.   Well get ready Consumers because the person that is about to visit your home IS NOT an...

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