21st July 2011

Last minute changes for the Consumer Finance Protection Bureau

The House voted Today to change how the Consumer Financial Protection Bureau is managed by passing legislation to install a five-member oversight panel to run the new agency instead of a single director.

The 241-173 vote – which came on the one-year anniversary of the Dodd-Frank financial reform bill will make it easier to overturn regulations imposed by the bureau.

That doesn’t sound like a very good solution, but I guess we will have to see at this point.

Congressional Republicans were happy with the prospect of the five-member commission stating one director is too powerful and not accountable.

…continue reading the rest of this post: Last minute changes for the Consumer Finance Protection Bureau

posted in Dodd-Frank C&R Topics | 0 Comments

21st July 2011

Appraisal Institute testifies before a Congressional subcommittee RE: C&R

Sara W. Stephens, MAI, Appraisal Institute’s president-elect, addressed the House Financial Services’ Subcommittee on Insurance, Housing and Community Opportunity that the Dodd-Frank Act passed by Congress last year is not being properly implemented by federal regulators in regards to C&R.

One provision within Dodd-Frank calls on appraisal management companies to pay “customary and reasonable” fees to real estate appraisers.

Unfortunately, the Federal Reserve’s Interim Final Rule is not faithful to Congressional intent. The Appraisal Institute thinks Congress’ intent was right on target. We urge Congress to guide the regulators’ aim, directing them to correct the Interim Final Rule to promote credibility over speed and cost.

…continue reading the rest of this post: Appraisal Institute testifies before a Congressional subcommittee RE: C&R

posted in Dodd-Frank C&R Topics | 0 Comments

20th July 2011

Consumers and Appraisers – Grab your ankles : Filibuster in progress

The senate is in charge and are holding up any nominee to head the Consumer Financial Protection Bureau.

Mike Konzal states

What are the strengths of the way the CFPB is structured in the Dodd-Frank Act? There are many, especially the consolidation of consumer regulation and focus on research. But three structural strengths stand out: it has a single director, there’s been careful attention paid to its budgeting process and it is just like other regulators in terms of accountability but with focus on consumer protection as its primary goal. These three parts of the CFPB were carefully planned, designed and fought for.

….[Those three] major strengths — a director, funding and accountability with a focus on consumer protection — are exactly what the Republicans want to dismantle. No doubt they are trying to stall and annoy the implementation of Dodd-Frank and prevent the CFPB from doing all its work — of course they are — but if there were three critical points where they could significantly weaken what the CFPB can do, these would be those three.

They are essentially violating their oath of office by promising to keep anyone from running the agency unless some changes are made.

So what does this mean to appraisers?

Nothing new and nothing being done about the ‘Customary and Reasonable Fee” provision enacted by Dodd-Frank.

As usual we are in another waiting game with our hands tied.

Troutman Sanders of the CFPB team stated

The appraiser fee and independence provisions contained in Dodd-Frank were designed to address concerns that lenders were using less expensive appraisal management companies (“AMCs”) hired or owned by lenders at the expense of independent, high-quality appraisals. As a result, AMCs may be a regulatory target of the CFPB after the Bureau’s July 21, 2011 transfer date.

The Bureau will assume rulemaking and enforcement authority for Dodd Frank’s appraisal fee provisions after July 21st. Notably, the CFPB will be enforcing Dodd-Frank’s penalties for lenders violating appraiser independence standards which are currently $10,000 a day for the first violation and $20,000 a day for each additional violation.

Again, I urge you to get involved. Stay up to date with the news and join your local appraiser coalitions! Contact your state licensing agency, congress and other regulators. Only together can we win this battle against the appraisal management companies that are destroying our industry.

Bryan Knowlton
California Real Estate Appraiser
http://www.appraiserincome.com

posted in Dodd-Frank C&R Topics | 12 Comments

21st June 2011

Appraisal Management Companies ‘might’ feel the wrath 07/21/11

April 1st came and went with no good news regarding Customary and Reasonable fees and what the AMCs are doing to the appraisal industry in whole. I believe it was little more than a coincidence that it was also April Fools Day.

May 21st came and went without the world coming to an end. I also find this a little more than a coincidence that the Consumer Finance Protection Bureau will be taking over rule-making and enforcement in regards to Dodd-Frank Customary and Reasonable fee provisions.

Either way I am excited!

I know a lot of the Appraiser Coalitions as well as the AGA will be …continue reading the rest of this post: Appraisal Management Companies ‘might’ feel the wrath 07/21/11

posted in Dodd-Frank C&R Topics | 10 Comments

23rd May 2011

Kuempel Bill passes in Texas Legislature

AUSTIN—Representative Kuempel (R-Suguin) passed house bill 1146 to establish a reasonable registration and regulatory structure for appraisal management companies operating within Texas.

As a result of the implementation of HVCC and the following outsourcing by many financial institutions to have appraisal management companies manage appraisers fulfilling appraisal assignments, the AMCs have grown tremendously over the years without any government oversight.

…continue reading the rest of this post: Kuempel Bill passes in Texas Legislature

posted in Dodd-Frank C&R Topics | 3 Comments

19th May 2011

TAVMA responds to Board of Governors of the Federal Reserve System

TAVMA
Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, Northwest
Washington, DC 20551

Re: Interim Final Rule – Customary and Reasonable Fee Stipulation

Dear Ms. Johnson:

The Title Appraisal Vendor Management Association(“TAVMA”) wishes to express its views about the misinformation being disseminated by appraisal organizations and publications about the Federal Reserve’s Interim Final Rule and Appraisal Management Companies (“AMC’s”). TAVMA is a national trade association of real estate settlement services providers including many leading appraisal management companies.

…continue reading the rest of this post: TAVMA responds to Board of Governors of the Federal Reserve System

posted in Dodd-Frank C&R Topics | 0 Comments

27th April 2011

Help the fight against low paying appraisal management companies by joining The American Guild of Appraisers!

The American Guild of Appraiser (AGA) /Guild 44 of the Office and Professional Employees International Union (OPEIU)/AFL-CIO is based in Maryland, a short distance from Washington, DC.

The AGA is a non-traditional union that represents independent professionals. The AGA does not engage in collective bargaining, strikes, and does not enforce closed shops. The AGA does not negotiate contracts, does not have shop stewards, and does not have any oversight regarding its member’s work products. What we have is the backing of over 10 million members within the AFL-CIO and 110,000 within the OPEIU. With these numbers, we have a collective voice.

…continue reading the rest of this post: Help the fight against low paying appraisal management companies by joining The American Guild of Appraisers!

posted in Dodd-Frank C&R Topics | 2 Comments

1st April 2011

All Appraisal Management companies now paying FULL FEE APPRAISALS

Wow! It is amazing. It looks like all the work banding together as an industry has worked. All the appraisal orders I received today were in the $300-$400 range! Dodd-Frank really came through on this one.

The federal government must have really put the scare in to the appraisal management companies and laid down the law.

The Appraisal Subcommittee even gave me a call back and sent out a few reply emails concerning my questions that were previously left unanswered prior to today, 04/01.

I guess I shouldn’t have been so opinionated regarding comments like ‘I won’t hold my breath’ and ‘business as usual’, etc…

Things really can be different, things really can change.

…continue reading the rest of this post: All Appraisal Management companies now paying FULL FEE APPRAISALS

posted in Dodd-Frank C&R Topics | 40 Comments

30th March 2011

April 1st is right around the corner

Do you think you will see much change regarding Customary and Reasonable fees come April 1st? It sounds like we are going to have to take up law school to straighten out this question.

Below is an article I received from WorkingRE.com on the subject of Customary & Reasonable Fees.

…continue reading the rest of this post: April 1st is right around the corner

posted in Dodd-Frank C&R Topics | 4 Comments

25th March 2011

CoreLogic VP speaks on upcoming changes to appraisal fees – customary and reasonable

Wednesday, March 23rd, 2011, 2:39 pm

David Feldman is vice president, government affairs at CoreLogic Valuations. He sits down with HousingWire to talk about the impending deadline on appraiser fees under new regulation.

HousingWire: On April 1, the new “customary and reasonable” appraiser fees under Dodd-Frank take effect. What are they and is the industry ready?

David Feldman: According to Dodd-Frank and the Interim Final Rule, appraisers must be paid at a rate that is customary and reasonable for appraisal services in the market area of the property being appraised. The IFR interprets the language of Dodd-Frank to signify that the marketplace should be the primary determiner of the value of appraisal services.

…continue reading the rest of this post: CoreLogic VP speaks on upcoming changes to appraisal fees – customary and reasonable

posted in Dodd-Frank C&R Topics | 46 Comments



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