Tagged: IRS

Insights from CFPB's Public Comment Period 53

Insights from CFPB’s Public Comment Period

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

Lack of Fee Transparency: Exposing the AMC Exploitation 71

Lack of Fee Transparency: Exposing the AMC Exploitation

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge.  Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

Uncovering Flaws in FHA Appraisal & Loan Review Process 28

Uncovering Flaws in FHA Appraisal & Loan Review Process

The story of this single mother’s harrowing experience with a defective home purchase and HUD’s negligent oversight exposes deep flaws in the FHA appraisal and loan review process. After sacrificing for years to rebuild her credit and earn the right to become a homeowner, this borrower found her dream home in the country – or so she thought. During the home inspection, several issues were flagged. The seller, an investor who had purchased the home in an estate sale, was unaware of the septic system’s location. The seller agreed to have the tanks pumped so the location could be determined....

Automatic Review of Photos in Appraisal Reports 22

Automatic Review of Photos in Appraisal Reports

It means the statements in your appraisal reports about the actual component material, and its quality and current condition, can be challenged by computer software.  Folks, this news release (below) was in several publications on Wed, June 19, 2024. These kinds of releases are mostly factual, but are often embellished to present a particular ‘owner’ point of view to influence opinion about products. I remember listening to Jeff Bradford many years ago who discussed the early stage process to electronically review photos. He said it was pretty difficult then. But that was before we began hearing about “A.I.” – artificial...

Alleged Racial Discrimination Debunked: Security Bars Removal Required by Law 15

Security Bars Removal Law Debunks Alleged Racial Discrimination

Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of “racist discrimination”… Security bars on bedroom windows is against code…  This morning I received the results of a California State Information Act Request I made regarding an alleged case of racial bias in Allendale, Oakland, California which was settled May 2024. I requested any and all documents in the case involving the appraiser because I didn’t have the complainant’s name or property address. I only had the appraiser’s name which I won’t post in text. Complainant stated appraiser told them they should...

Gov't-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm 14

Gov’t-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm

The U.S. government impoverishes homebuyers as it does the chronically ill – by promoting the use of middlemen who prey upon them. A cadre of such middlemen was created decades ago as a firewall between Big Pharma, the insurance companies and the pharmacy chains. Called “pharmacy benefit managers,” they were to negotiate drug prices, streamline distribution and manage lists of prescription drugs covered by insurance plans. But since the government has gone whole-hog into health care under the Affordable Care Act and into drug-price controls under the Inflation Reduction Act, things have gotten crazy at the slop trough. Today, according...

Appraisal Fees & Value: Lessons from Picasso & Steinmetz 26

Appraisal Fees & Value: Lessons from Picasso & Steinmetz

Picasso answered “$5,000 madam.” “But it only took you five minutes.” “No, madam, it took me my whole life.”  The Appraisal Institute has been a source of frustration and criticism within the appraisal profession for quite some time. I must admit that I have also expressed my dissatisfaction with them. Nevertheless, I must acknowledge that the new CEO, Cindy Chance, appears to be a positive change and is making some valuable points about our profession from her new position. In particular, she recently discussed appraisal fees in a piece she wrote. In this excerpt, she shares two stories that provide...

Fannie, Freddie's Offshore Gambit Imperils Privacy of Millions 37

Fannie, Freddie’s Offshore Gambit Imperils Privacy of Millions

The offshore firm will data-mine millions of images showing the personal spaces of U.S. homeowners and tenants.  Fearing the Chinese government could access sensitive user data through the video app TikTok, House lawmakers passed a bill last month that would ban the app if it isn’t sold to new owners. But a greater peril looms. Mortgage giants Fannie Mae and Freddie Mac are reportedly “bench-testing” an arrangement with a foreign AI firm in which the offshore firm will data-mine millions of images showing the personal spaces of U.S. homeowners and tenants. If your home was appraised for a refinance or...

Fannie & Freddie's AI Appraisal Photo Recognition 46

Fannie & Freddie’s AI Appraisal Photo Recognition

A colleague recently shared an important heads up regarding Fannie Mae and Freddie Mac’s plans to implement photo recognition AI to analyze appraisal photos. This technology can scan a single photo and extract over 100 data points related to quality, condition, and repairs. For example, it can identify flooring types, appliance models, and even assess light levels in a room. Later this year, the GSEs plan to run all appraisal reports through this AI and cross-check the appraiser’s stated quality and condition ratings. If the AI’s analysis differs significantly from the appraiser’s, it will automatically generate a complaint letter to...

Government-Sponsored Mortgage Giant Fannie Flouts Law 17

Fannie Wants to Script Conclusions of Outside Analyst – Believes It Is Above the Law

Government-sponsored mortgage giant Fannie Mae is essentially forcing banks to repurchase any loan it wants if [the appraiser] refuses to use the comparables Fannie has selected.  [The corporation] was created by the government, is controlled by the government, and operates for the government’s benefit,” wrote Justice Anthony Kennedy in a unanimous Supreme Court ruling in 2015. He was describing passenger rail hegemon Amtrak, but he could easily have been describing government-sponsored mortgage giant Fannie Mae. The Roberts Court held the National Railroad Passenger Corporation – known more commonly as Amtrak – was a government entity for the purposes of the...

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