Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551
Re: Docket No. R-1394 and RIN No. AD-7100-56
Thank you for the opportunity to comment on the Interim Final Rule (IFR) amending Regulation Z (Truth in Lending) and the matters of appraiser independence and customary and reasonable fees to appraisers. In reviewing the rule it is clear that the Federal Reserve spent considerable time in preparation of the IFR. The agency is to be commended for its hard work, especially for meeting a very strict and difficult deadline and given other agency resource constraints.
Now this is one amazing fee report. Hopefully this is enough to signify what is median and average fees as observed between clients and independent fee appraisers when specifying the Uniform Residential Appraisal Report, or URAR. It provides statistical data on hundreds of thousands of URAR transactions at the national, regional, and state levels, covering all 3,221 counties and local administrative districts in the fifty United States, the District of Columbia, Puerto Rico, and Guam.
On December 27, the American Society of Appraisers, together with the National Association of Independent Fee Appraisers (NAIFA), the Appraisal Institute (AI) and the American Society of Farm Managers and Rural Appraisers (ASFMRA), filed reply comments with the Federal Reserve regarding its proposed Appraiser Independence Interim Final Regulations.
Of utmost importance to ASA and our partners was concern over the potential for “the consideration of fees paid by AMCs when adhering to the first presumption of compliance with the customary and reasonable fee regulations,” which uses a series of factors in determining whether the fee paid to an appraiser is appropriate under the law and regulations. This concern arose from commentary provided by the Fed in its Interim Rule which stated that determining whether an appraisal fee is customary and reasonable, “does not require that a creditor use third-party information that excludes appraisals ordered by AMCs.”
In this episode I talk about a super time saving piece of software that I have been using. It has been about a month and I am loving it! It cuts a ton of time off my appraisal report typing by putting in all my subject and comparable information as well as helping to complete the 1004MC and REO Addendum.
There are so many ways to customize DataMaster to fill out your appraisal reports. You can read all about it at http://datamasterusa.com/. There is a free trial, so make sure you sign up and at least give it a try.
If you are looking for immediate San Diego Appraisal services by a certified and insured San Diego Appraiser, please visit http://www.appraiserincome.com
I provide appraisal services throughout San Diego County for:
Date of Death Appraisal Services
San Diego Divorce Appraisal
San Diego Bankruptcy Appraisal
Tax Reassessment Appraisals
Appraisal services for Bail
Please Contact Bryan Knowlton
The Federal Housing Administration has published its Winter edition of the FHA Appraiser Roster Newsletter.
In This Newsletter they cover:
• Interagency Appraisal and Evaluation Guidelines
• FHA Spotlight –
Actual Appraisal Reviews
• Coastal Barriers Resources Act
• New Puzzle
• Answers to Last Quarter’s Puzzle
• New FAQs
Thank you for signing up to the Appraiser Marketing System!
You are going to be really glad you did. I really can almost guarantee if you follow the steps that I outline, you will definitely make more money as a real estate appraiser. I have been using these techniques for years, as well as adding a some new ones when it comes to getting the most out of the Appraisal Management Companies.
This system will teach you how to successfully market your Appraisal Business to get more appraisal management offers from multiple AMCs and give you the ability to cherry pick the best assignments.
You will also learn how to get the cream of the crop, estate orders, and hopefully give you the ability to be less reliant on AMC work, possibly moving completely away from the AMCs if there is enough estate work in your area. All it takes is 1 good client to provide tons of estate orders!
I originally tried to make my system available 100% via Email notifications, but this became a problem due to the length of the emails. I also wanted the ability for people to ask questions or to share their experiences. So when you get an email from me, you will eventually need to click on a link which will take you to this website to finish the lesson for that day.
I always want to help out, so if you have any immediate questions, please post it below! I will answer them as soon as possible.
Thanks again for joining and I will email you within the next week with the start of the Appraiser Marketing System!
Wow, it has been a really slow month so far, but I am still getting quite a bit of requests per week for appraisal assignments and I am completing between 5-10 reports a week. My market is fairly big with over 1M in the city of San Diego and over 3M county wide.
Things should start picking up and be going full force by March according to the top appraisal management companies.
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No More Middlemen & 2019 AMC Directory
Get both Directories and we will even throw in a copy of the Maximizing AMC Orders and Income eBook for free!
Significantly Discounted and on SALE right now. Original Cost for all 3 = $184.95
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2019 Appraisal Management Company Directory and additional chapters on recession proofing your appraisal business, getting more estate appraisal requests and search engine marketing.
First 37 on the list send the most work, First 10 on the list are currently my BEST clients.
Non-Lender Marketing Guide & Spreadsheets
2019 Appraiser Marketing Guide and List of 11,000+
Direct Lenders, Credit Unions and Bail Bond Companies. Get off the AMC roller coaster ride for good!
Appraiser Income provides Appraiser Marketing Tips and Advice and publishes an annual Appraisal Management Company Directory.
Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.
The free marketing tips and advice offered on this website is in no way implying a guarantee of income. We do not assume responsibility for any profits or losses based on your marketing efforts. The AMC Directory and No More Middlemen Guides both provide a list of companies you can market your services to. But we do not guarantee you will receive orders or make money from them. These are trade publications with a list of the companies and marketing tips and advice that I use to make money as a real estate appraiser. Your results will vary.