Tagged: RESPA

AMC Rules Inconsistent with Congressional Intent - Banking Agencies 2

Agencies AMC Rules Lack Guidance

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

AMC / American Society of Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Where Did All the Good Appraisers Go - Imagecredit Flickr - gerlos 5

Where Did All the Good Appraisers Go?

The good appraisers are leaving mortgage appraising as fast as they can. Thus far the housing industry has been applying “Band-Aid” solutions to the bigger real estate crisis. There are several problems going on at the same time, all contributing to the big picture, which is bleak to say the least. One true crisis in the real estate industry is an “information crisis.” This information problem, trickles down to appraisals, lenders, and ultimately, mortgage investors. Standardization, national guidelines, and disclosures are the only way back from this nightmare (i.e. the RESPA disclosure. One fee on the good faith estimate for...

AMC / Appraisal / Appraisal Management Companies / Customary & Reasonable Fees / Dodd-Frank Act / C&R Fees / Home Valuation Code of Conduct

4

Mortgage Disclosure Rule Alters Appraisal Fee Reporting

The Appraisal Institute on Dec. 17 finalized its review of the Consumer Financial Protection Bureau’s 1,888-page final rule on Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act and the Truth in Lending Act, and noted several provisions that impact real estate appraisers and how appraisal fees are reported. The rule, which takes effect Aug. 1, 2015, mandates the use of two new disclosure forms, the Loan Estimate (which replaces both the Good Faith Estimate and the initial Truth in Lending Disclosure) and the Closing Disclosure (which replaces both the HUD-1 and the final Truth in Lending Disclosure). It...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

Lenders May Still Profit Most from Appraisal Fees 2

To Disclose or Not to Disclose AMC Fees

To Disclose or not to Disclose AMC Fees… With the Consumer Financial Protection Bureau (“CFPB”) up and running, there are numerous regulatory issues still pending relating to the Dodd-Frank Act. The regulatory issues include appraisal independence rules, AMC fee disclosure, AMC registration, required physical property visit by appraisers in “higher risk” mortgages, HUD-1/RESPA Consumer Disclosure, and asset backed securities. Of particular note, the CFPB has proposed a new Consumer Disclosure form that is intended to replace the HUD-1 settlement statement. The proposed rule which was release for public until November, allows disclosure of appraisal management company fees, but does not...

AI / AMC / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal Management Companies

NAIHP Exposes AMC Tax Evasion / RESPA Violations 1

NAIHP Exposes AMC Tax Evasion / RESPA Violations

AMCs violating RESPA NAIHP recently discovered many Appraisal Management Companies (AMC’s), are operating without authority in most states and have failed to pay state income tax. When businesses are formed, they are required to register with their Secretary of State, for authority to conduct business. That registration alerts the State Tax Department you exist and may be responsible for certain taxes. The same holds true if you operate outside your home state, according to Marc Savitt, NAIHP President. “Most AMC’s are only registered in a handful of states, but operate nationwide. If you’re not registered, you’re not paying taxes,” said...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Home Valuation Code of Conduct

xml sitemap
blank