Disclosures regarding payments for appraisal management services versus appraisal fees On July 1, 2015, the Network of State Appraiser Organizations (NSAO) submitted a joint letter in response to the CFPB request for comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015. It specifically addresses the lack of requirement to mandate disclosure to the consumer that the fee paid for an “appraisal” be clearly defined and break down what portion is being paid to the lenders’ third party appraisal management company and which portion of the fee is...
Network of State Appraisal Orgainzation’s letter to FHFA Director Watt Regarding Fannie Mae Collateral Underwriter (CU) Program For over the past couple of months, VaCAP has participated with 18 other State Appraiser Coalitions in drafting an unified response to Fannie Mae’s Collateral Underwriter Program. Their letter to FHFA Director Watt briefly outlines their concerns, offers recommended solutions, as well as asking for a meeting to discuss the issue for the benefit of all vested parties. Please take a few minutes to peruse the letter below: Dear Director Watt: On behalf of the independent state professional appraiser organizations signing below, I...
Representatives of several independent state professional appraiser organizations met in Chicago, Illinois on Saturday October 11th, to further discuss collaboration on issues affecting their membership. The network, which started as a conversation among three State appraiser organizations less than a year ago, now comprises 16 such State Organizations which is expected to continue growing. The group, which functions as a network rather than a formal organization is unique in its focus and operation. The network has no single elected leader but is comprised of leaders from each participating state organization; it is self-governing by consensus. Participating organizations do not pay...
The Appraisal Profession & Appraiser’s Business Decimated by the Increasing Dominance of Appraisal Management Company Services (AMCs) For the past two months, VaCAP has participated in a networked council consisting of 13 professional state appraisal organizations in responding to the Agencies request for comments of the Proposed Rules on Minimum Requirements for Appraisal Management Companies: Dear Agencies; This letter is in response to the Agencies’ request for comments on the Proposed Rules on Minimum Requirements for Appraisal Management Companies. The undersigned represent a networked council of professional state appraisal organizations. We appreciate this opportunity to comment and thank the Agencies for...
