Tagged: requirements

Beware of Appraisers Point Solicitations 65

Beware of Appraisers Point Solicitations

Appraisers, a new ‘company’ with “Appraisers Point” in their name has been marketing their services via emails across the fruited plain lately, encouraging appraisers to sign up on their web site and pay an annual fee so that ‘you’ can get on a list to be presented to, or accessed by, unnamed lenders, who might, or might not, want your service. They have a very slick looking web site that makes them look legit. Appraisers Point has no location shown on their website, so in reality, it could be anywhere in the world. The email messages show a location in...

We the Owners Are the Only Ones that Can Fix Low Appraisal Fees 59

Customary and Reasonable Fees?

…appraisal firm owners roll up your sleeves & hold the line on fees… I have been the owner of HF Appraisal Ltd since 1993 and I have sat on the sidelines in regards to Customary and Reasonable appraisal fees. I can no longer stand by and read nor hear about this issue. It is amazing to me that over the past five to ten years our fees have remained the same and in some cases are lower than they were 10 years ago. The more that I read about this and talk to appraisers across the country in classes and...

Comments Needed for Proposed Rule to Amend Appraisal Requirements 8

Comments Needed on Appraisal Requirement

The OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies’ regulations requiring appraisals for certain real estate-related transactions. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices. The proposed rule would make conforming changes to add transactions secured by...

Proposal to End Appraisal Requirement on Home Sales of $400k or Less 50

Proposal to End Appraisal Requirement

Regulators’ Proposal to End Appraisal Requirement on Some Home Sales of $400,000 and Below… The Federal Deposit Insurance Corp., the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve released a proposal that would increase the appraisal requirement from $250,000 to $400,000, meaning that certain home sales of $400,000 and below would no longer require an appraisal. According to data provided by the FDIC, the agencies estimate that increasing the appraisal threshold from $250,000 to $400,000 would have exempted an additional 214,000 residential mortgages at regulated institutions from the agencies’ appraisal requirement in...

When an Appraisal is Not Required - Appraisals & Evaluations Regs 8

Appraisals NOT Required

…is not required to obtain an appraisal under other law… The Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter to US banks on 10/16/18, which incorporates Appraisal and Evaluation regulations and guidelines. This consolidates previously issued regs and guidelines into one document: Letter  FIL-62-2018 Part 323 – Appraisals Appraisal and Evaluation Guidelines 2000 – Rules and Regulations PART 323—APPRAISALS § 323.3 Appraisals required; transactions requiring a state certified or licensed appraiser. (a) Appraisals required. An appraisal performed by a state certified or licensed appraiser is required for all real estate-related financial transactions except those in which: (1) The transaction value is $250,000 or less;...

TALCB States 70% of All Complaints Against Appraisers Are Unfounded 118

Frivolous Complaints Against Appraisers

TALCB noted that roughly 70% of all complaints against appraisers are unfounded… The American Guild of Appraiser recently wrote to Texas Sunset Commission expressing member concerns and suggested solutions. We urge readers to copy, paste, edit and send their own comments – even out of state appraisers. Click here to send your comments. Posted AGA comments and concerns Appraiser complaints are allowed to be filed against appraiser by third parties that are not the clients. The appraiser has no recourse to these for recouping costs of defense. Third party complaints by non clients (agents; brokers, buyers, sellers) serve only to...

The C&R Compensation Argument - Audit AMCs for C&R Payment Compliance 24

The C&R Compensation Argument

Audit amc’s for C&R payment compliance nationally… A wrongful denial of that immunity is effectively unreviewable because it subjects states and related entities to the indignity of defending sovereign action through protracted litigation. Delaying appeals or orders denying state action immunity will interfere with their regulatory freedom by distracting officials from their duties and hindering their discretionary actions. Please allow me to help with a summary of the past 10 years in the appraisal industry. Amc’s are billion dollar companies and they circumvent many long standing ethic and spirit of regulatory compliance laws in states where they operate. They shop...

Photo of Comps When People or Children Are Present - Standing Rule 75

Did That Guy Just Take a Picture of My Kids?

Looking at the tricky question of taking photo of comps when people are present… I want to talk to you today about something most of us appraisers do on a daily basis – taking comparable photos. Now, I don’t want to get into the whole “Are comps a waste of time? Do they actually serve any purpose?” debate. That’s gone on long enough and it isn’t going to stop any time soon. Instead, I want to try and clear up what is and isn’t actually required from your FHA comps; specifically, we’re going to be looking at the tricky question...

Prizes Awarded for Correctly Identifying AMC in Appraiser Contest 37

Appraiser Contest

…multiple prizes will be awarded…correctly identify this LandSafe-like wannabe to win ANNOUNCING NEW APPRAISER CONTEST! Look at the following time requirements from one national [anonymous] AMC. These requirements are so outrageous that advance disclosure to their clients should be a requirement that their policies suborn appraisers to ignore USPAP and encourage appraisers to take improper short cuts. Here’s the challenge… I have redacted the name of this unprofessional company that appears to think their drive to offer what their competition cannot, (or more likely won’t) warrants promoting subpar appraisal practices. All you have to do is correctly identify this LandSafe-like...

Community Banks Appraisal Waivers Deja Vu - If I Could Turn Back Time 61

If I Could Turn Back Time

Community Banks want to bypass appraisals in rural area… Evaluations are the answer, right? There have been lots of discussions lately concerning property inspection waivers, waivers of appraisals in rural areas, and allowing appraisers to complete Evaluations outside of USPAP standards. Doesn’t this all sound familiar? It should, we have already lived it 30 some years ago, prior to FIRREA. Back then Savings and Loans had staff appraisers to complete appraisals. The appraisal was not completed by a licensed appraiser, because licensing to protect the public did not exist. Today Community Banks want to bypass appraisals in rural area. Their...

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