Tagged: TILA

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages 38

Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

ACI / AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News

36

Twisted AMC & C&R Fees Gone Wrong!

This AMC is Just Wrong & Confused! An AMC sent an appraiser the following email this morning: “…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“ Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

Low AMC Fees? FDIC Wants to Hear from Appraisers 24

Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers

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...

Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / Customary & Reasonable Fees / Dodd-Frank Act / C&R Fees

Truth-in-Lending Act - RESPA Ingetraged Disclosure - TRID Coming Soon Imagecredit Flickr - Dennis Skley 1

TRID Coming Soon Your Way

Appraisers and others, TRID is coming to mortgage lending on Aug. 1, 2015. In case you have not been paying attention to new aspects surrounding your typical measuring buildings and writing reports on a daily basis, TRID is set to become a major change in the mortgage lending process. TRID is the acronym for the ‘Truth-in-Lending Act/RESPA Integrated Disclosure’ process that applies to every mortgage loan as of 8/01/15.  It was part of the Dodd-Frank Law, with power given to the CFPB agency to devise the rules, forms and process. The intent is to consolidate and simplify processes that have...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

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Residential Appraisers Dos and Don’ts

Residential appraisers are a critical piece in the puzzle that is determining a property’s “true” value. But in today’s market, the role they play is more pivotal than ever. When every dollar counts (as the players of the game may still be licking their wounds from the oh too recent housing crisis) sellers want to be able to get the highest value possible for their property and buyers certainly do not want to overpay for a home, so working with an appraiser who is trained to perform services in an ethical and professional manner with rich knowledge of the market...

Appraisal / Appraisal News / Appraisers News / Uniform Standards of Professional Appraisal Practice / USPAP

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

In response to appraisers under attack 2

In Response to “Appraisers Under Attack”

In response to Frank Garay and Brian Steven’s commentary (see video below), on the lawsuit against TriMavin AMC over alleged appraisal independence violations, an anonymous commentator posted the following: There are a number of posters here who need to re-take their CE classes including the moderators. Here are the reasons the entire industry is severely broken. I mean from the Realtor to the Appraiser to the Mortgage Lender. First of all HVCC sunset folks – back in 2010. It was replaced with AIR (Appraiser Independence Regulations) and the Dodd Frank Act. Cannot tell you how irritating it is to me...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

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Questions & Comments RE Customary and Reasonable Fees

Where To Direct Questions and Comments Regarding Customary and Reasonable Fees The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Subcommittee

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