ICAP commented on the impending Interim Final Rule that will allow real estate appraisals to be deferred for 120 days for certain real estate transactions. The letter states that the deferment could lead to several unsettling possibilities. The letter implores the agencies to reconsider this rule. Now is not the time to walk away from safety measures meant to insure the present and future movement of real estate, but to embrace them. Public Trust is the appraiser’s primary concern. To not have this certified and insured professional involved at the outset of real estate lending during this time, in some...
Appraisers reluctant to force actual C&R fees on AMC clients… Appraisers, I’ve spent the last two days reviewing the ‘new Rule’ involving the registration of AMCs, which has – buried within it by reference – information relating to Customary and Reasonable Fees for appraisal reports. I’m grateful to an appraiser acquaintance in Pennsylvania for her assistance. Below is a 4 page document that shows the mentions of “C&R Fees” – and how those apply to AMCs. You may forward this to anyone else, or may use this information in any article or publication disseminated to appraisers, lenders, AMCs, other clients...
REASONABLE needs to become the appraiser’s operative word Appraisers, It’s time to grow a pair as some people say, or to stiffen the backbone, and quit caving in to the low ball fees being offered by some in this crazy “industry.” Another true statement is “you are what you are worth”. If you, as an business person, only know how to say yes to low fees, you won’t be worth anything higher to the majority of clients. Further, your self image and actual net worth are negatively impacted. You cannot expect to earn a certain income, then wonder why you gave yourself...
A Cost-Plus fee structure will allow the Customary and Reasonable Fee provision, a component of Appraiser Independence, to be more readily adopted. Fellow Professional Appraiser, I am asking you to take a moment from your busy day to PARTICIPATE in an important industry effort. That issue is referred to within Title XIV of the Dodd-Frank legislation as “Customary and Reasonable Fees”: CUSTOMARY AND REASONABLE FEE In General – Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such...
NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...
The National Association of Independent Housing Professionals (NAIHP) led by Marc Savitt is petitioning the Consumer Financial Protection Bureau and is asking those harmed by the Interim Final Rule on Appraiser Independence to sign and forward the online petition. To Consumer Financial Protection Bureau (CFPB), Richard Cordreay, CFPB Director: Allow NMLS loan originators to order appraisals directly from appraisers Consumers and small business are being significantly harmed by the Interim Final Rule on Appraiser Independence. Consumer costs have increased by over 2.8 Billion dollars a year; thousands of small business residential appraisers have gone out of business, as the rule diverts...
