Regulation Z - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

Guest Author — Mon, 31 Aug 2026 12:30:57 +0000

Why It Matters Appraiser independence is mandated by state and federal laws – not a professional courtesy. Every agent, broker, loan officer, lender and AMC involved in a transaction with a lender-ordered appraisal is legally prohibited from influencing the appraiser’s value conclusion and from interfering in the appraisal process. Violations can cost you your license, trigger federal civil penalties, NAR sanctions, civil liability, and in extreme cases, criminal prosecution.1 “I didn’t know” is not a defense. The Legal Foundation Three federal frameworks govern this area. Title XI of FIRREA (1989) requires all appraisals for federally related transactions to be performed...

Violating Appraisal Independence Through Harassment,… It shall be unlawful... to engage in any act or practice that violates appraisal independence... Appraisers, I have written the…
Expert Wants to “Eliminate” Appraisers Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with…
No I Won't Work With This Appraiser How much power do agents have over the appraisal process? The lender gets a call. Agent tells them that appraiser…

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A Cry from the Appraisal Trenches: The Fall of GSE Oversight

Guest Author — Fri, 25 Apr 2025 12:30:13 +0000

That could bring our best and brightest back to GSE lending, leveling the playing field with fairer work distribution. Picture this: a system built to protect homeowners, backed by taxpayer dollars, now teetering on the edge of betrayal. The regulatory framework governing Government-Sponsored Enterprises (GSEs) was once a fortress of consumer protection, transparency, and fairness. As an appraiser, I’ve watched this fortress crumble. The rules imposed on GSEs and their partners—our trade-off for their congressional charter—have been chipped away through years of cunning maneuvers by trade groups and stakeholder interests. What’s left is a hollow shell, far removed from the...

Data Cancer Infecting the Real Estate Market They have created the phenomenon known as “data cancer” which reduces an appraisal to a rubber stamp that contaminates the…
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…
The One-Mile Rule: Prudent Policy or Modern Day Redlining? ...whether through redlined maps or implicit "one-mile rule," the result can be undervalued properties in historically marginalized neighborhoods. Throughout the…

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Another Threat Looming

Dave Towne — Sun, 18 Mar 2018 12:30:56 +0000

Senate Bill raising de minimus value to $400,000 will also waive appraisals in certain situations in rural areas Folks, while the TriStar Bank appraisal waiver issue is important for appraisers, there is another insidious threat looming: Senate Bill 2155 passed the Senate this week, and is now in the hands of the House of Representatives. That bill, if fully ratified as it stands, and is signed by the President, will undercut the need for appraisals in two ways: the current de minimus value of $250,000 is raised to $400,000, which means lenders can use non-appraiser evaluations to establish property value for...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…

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Dangerous Pending Bill in US Senate

Dave Towne — Fri, 09 Feb 2018 13:30:40 +0000

Appraisers, If you work in Rural Areas [that definition is referenced in (b)(1) below], your appraisal livelihood is threatened by this pending bill in Congress. This bill, if signed into law, will allow lenders to bypass appraisals for any property with a ‘transaction value’ of $400,000 or less (this is moving the de minimus goal post) if the lender was unable to find an available appraiser to complete an appraisal “within a reasonable amount of time”… that time frame apparently as determined by a regulator agency with jurisdiction over the lender. The bill shows ‘exceptions’ to this as per other laws. Appraisers...

Another Appraisal Waiver Request Another Appraisal Waiver request has been sent to the ASC. This time from City Bank and Trust in Oklahoma. The…
Appraisal Waivers vs. Public Trust If the ASC grants the request for appraisal waivers, the precedent will have been set for other banks to follow...…
Appraiserville - Fake Claim of An Appraisal Shortage Please provide feedback immediately to “two banking institutions have requested that the Appraisal Subcommittee temporarily waive the requirement for use…

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Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

VaCAP Board — Fri, 17 Jun 2016 12:30:26 +0000

AMCs paying low fees, Appraisers and Regulation Z of TILA VaCAP recently learned of some encouraging news. The FDIC wants Regulation Z to be followed and will enforce it for appraisers. Here is what VaCAP received from an appraiser who reached out to the FDIC: I just had a call from an extremely pleasant lady named Susan Welch from the FDIC Consumer Response Center (1-800-378-9581). I had sent a note over regarding an AMC attempting to get me to sign a “Base Fee Letter” agreeing to a drop of my base fee for full appraisals to $325 from $400-500. She...

Mr. $225 Appraiser and VaCAP Mr. $225 Appraiser, you are a major contributor to the problem Recently VaCAP has been receiving correspondence from Virginia Appraisers…
Compliance Notification to AMCs Virginia Coalition of Appraisal Professionals' Courtesy notification to AMCs licensed in Virginia On Monday March 29, 2016, VaCAP sent via…
The Appraiser is the Only One Policing the Industry Paid Late, Non C&R fees, Operating Without License AMC Violations VaCAP has learned North Carolina has disciplined Appraisal Nation and…

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Regulation Z - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

Related Posts:

A Cry from the Appraisal Trenches: The Fall of GSE Oversight

Related Posts:

Another Threat Looming

Related Posts:

Dangerous Pending Bill in US Senate

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Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

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