The Federal Deposit Insurance - Appraisers Blogs

County Assessors’ Standards | AVM Final Rule Guidance

Dallas T. Kiedrowski, MNAA — Fri, 23 Aug 2024 12:30:47 +0000

County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach. The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...

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Dazzled by Wizardry, Federal Mortgage Regulators Ignore Zillow Debacle

Jeremy Bagott — Mon, 12 Jun 2023 12:30:18 +0000

This rulemaking is one more sign that federal bureaucrats are all in on a whacky plan to use technical wizardry to tease out the value of individual properties across the country… Secretary of Defense Robert McNamara was a committed technocrat. Under his direction, a team of policy advisors descended into the Pentagon’s cavernous basement in 1967. They fed punch cards into the basement’s IBM mainframe computers with everything that could be quantified about the Vietnam War. Numbers of ships, tanks, transport helicopters, gunships, fixed-wing aircraft, artillery, troop strength, machine guns, ammo. They queried the computers, “What year will we win...

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Bias in Automated Valuation Models

VaCAP Board — Mon, 28 Feb 2022 13:30:35 +0000

The CFPB is reviewing bias in Automated Valuation Models (AVMs). The proposed rules are a joint effort by the Consumer Financial Protection Bureau, the Office of the Controller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Federal Housing Finance Agency. These agencies are concerned AVMs may reflect bias in design and function. The mathematical models rely on biased data resulting in inaccurate valuations. Basically the agencies are stating historical data going back to redlining is built into these models and do not reflect current market data. Remember markets are not static and are...

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TAF Is About To Get PAVEd

Jonathan Miller — Thu, 12 Aug 2021 12:30:33 +0000

The current administration is addressing the lack of diversity in housing valuation head-on with the formation of an interagency task force on Property Appraisal and Valuation Equity (PAVE). Here are the details of the PAVE Task Force. They just had their first meeting and this is a serious effort unlike the silliness of TAF’s bureaucratic actions of the past year that were nothing more than window dressing to the lack of diversity problem within the appraisal industry. Incidentally, The Appraisal Foundation is not part of PAVE Task Force. Keep that in mind when you read their bat-shit crazy letter again and think about the fact that...

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Reconciling the Erosion Within My Profession

Maureen Sweeney — Wed, 09 Sep 2020 12:30:02 +0000

The continued reliance of unregulated aggregators and bifurcated products continues to erode the public trust at the expense of discarding the profession specifically intended to promote the public trust. How does this protect the public?… On June 14, 2005 Steve Jobs told a class of graduates, “you can’t connect the dots looking forward; you can only connect them looking backward” Around the same time, I was appointed as the sole residential member of the appraisal licensing board of my state. Little did I realize that this 2005 governor-appointed position would eventually lead me to sharing a stage in 2018 with...

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AMC Liability for Deficient Appraisals

Peter Christensen — Mon, 17 Feb 2020 13:30:52 +0000

…may AMCs be liable for the deficient work of contractor appraisers? Can AMCs be sued for negligence? Can they be sued by borrowers?.. It’s now been a decade since the market relevance of appraisal management companies surged in connection with the procuring of appraisals for residential lending. Since then, interesting recurring legal issues have arisen relating to AMCs’ potential liability for the work of contractor appraisers: when and how may AMCs be liable for the deficient work of contractor appraisers? Can AMCs be sued for negligence? Can they be sued by borrowers? Here’s an overview of the answers to these...

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FIRREA Under Attack!

VaCAP Board — Thu, 13 Feb 2020 13:30:15 +0000

…the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for which an appraisal is required… Congresswoman Maxine Waters and Congressman William Lacy Clay request a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. The letter to Gene Dodaro, Comptroller General, Government Accountability Office, addresses threshold increases, regulatory exemptions, appraisal waivers, the North Dakota appraiser certification waiver and evaluations in lieu of an appraisal. It is clear the Chairwoman of the House Financial Services Committee and Subcommittee Chairman on Housing, Community Development and Insurance...

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De Minimus Impact on the Appraisal Industry

Dave Towne — Thu, 22 Aug 2019 12:30:53 +0000

THREE changes to the de minimus have been experienced, with very little negative impact to appraising as a whole… Folks, anytime there is a major change proposed or activated within the appraisal profession, many appraisers go into hyperventilation mode. The action taken on August 20, 2019, by the FDIC to raise the de minimus LOAN VALUE from $250,000 to $400,000 has had such an effect among many, but it may not be as dire as anticipated. An appraiser sent this 2018 HousingWire article to me earlier today: Within the body of the article, this is stated, which is taken from...

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FDIC Says NO to Appraisals

VaCAP Board — Wed, 21 Aug 2019 12:30:22 +0000

The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...

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Federal Agencies Changing FIRREA

VaCAP Board — Sun, 18 Aug 2019 12:30:47 +0000

VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraisal waivers in North Dakota. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies...

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Should We Raise the Deminimus to $2 Million?

George Dell — Tue, 29 Jan 2019 13:30:21 +0000

Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF. USPAP compliance is required for federally related transactions. USPAP comprises two parts:...

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Increased Regulatory Persecution of Appraisers

Michael Ford — Tue, 22 Jan 2019 13:30:04 +0000

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations. I was recently asked to consider a proposed change to USPAP. As received in my email: “Also this, in the 3rd exposure draft 239 The appraiser is not required to title an appraisal report using specific terminology because 240 USPAP compliance is measured by the substantive content of a report, not by what the 241 report is called. The use of labels such as analysis,...

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Comments Needed on Appraisal Requirement

VaCAP Board — Mon, 10 Dec 2018 13:30:20 +0000

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...

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Let’s Get Rid of Appraisers. What Could Go Wrong?

Ryan Lundquist — Fri, 30 Nov 2018 13:30:22 +0000

Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened. It Is Now Time To Listen Again as History is About to Repeat Itself. There’s a proposal from the FDIC, Federal Reserve, and Treasury Department not to require appraisals for some mortgages under $400,000. The Trump Administration wants to disrupt the role of appraisers, but that’s not a good idea. This change can impact several groups in particular: 1) Consumers: Removing appraisers from transactions can mean a lot of loans get made that shouldn’t be made. Does that sound familiar? We...

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Proposal to End Appraisal Requirement

ICAP Board — Fri, 23 Nov 2018 13:30:10 +0000

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...

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Appraisals NOT Required

Dave Towne — Tue, 23 Oct 2018 12:30:25 +0000

…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;...

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LREAB Response to FTC Allegations

LREAB Board — Fri, 02 Jun 2017 12:30:10 +0000

FTC seeking to punish LREAB for following federal regulatory mandates… BATON ROUGE, LA (May 31, 2017) – In an administrative complaint filed today by the Federal Trade Commission (FTC), it was alleged that the Louisiana Real Estate Appraisers Board (LREAB) had fixed the minimum price of residential real estate appraisals by enforcing the Board’s obligations under federal law to ensure that appraisers are paid customary and reasonable fees for their services. Bruce Unangst, Executive Director of the Louisiana Real Estate Appraisers Board (LREAB), said: “Respectfully, the FTC is just plain wrong. By issuing this legally faulty and factually incorrect complaint,...

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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...

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FFIEC Requested Action on TRID

AppraisersBlogs — Thu, 29 Oct 2015 12:30:47 +0000

The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...

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Beware of Appraiser Karma – Llano Cases

Peter Christensen — Wed, 14 Oct 2015 12:30:44 +0000

In our world of claims involving appraisers, we quite often see different versions of this same story — in this version of the story, an appraiser did a review appraisal that was used by Savant LG in a currently pending case against another appraiser in Florida. Just months later, that appraiser found himself named as a defendant in a lawsuit filed...

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