Appraiser Income

This past February, the American Society of Appraisers and the National Association of Independent Fee Appraisers (NAIFA) contacted the Consumer Financial Protection Bureau to explain the importance of itemizing the separate fees collected in the appraisal process for the prototype Good Faith Estimate (GFE) and settlement forms.

The CFPB continues to test different variations of the forms, the ASA and NAIFA sent another letter to reiterate the importance of separating the AMC fees from what is paid to the appraiser.

read the letter here:
March 30: Read the NAIFA and ASA Follow-Up Letter to CFPB Re: Disclosure of AMC Fee on Revised GFE/Settlement Form

Implementing the Dodd-Frank Act: The Federal Reserve Board’s Role
The Federal Reserve Board is responsible for implementing numerous provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act” or “DFA”), sometimes in conjunction with other government agencies. Listed below are the implementation initiatives recently completed by the Board, as well as several of the most significant initiatives that the Board expects to address over the next few months. Timeframes for upcoming initiatives are estimates and may be adjusted.

Initiatives Completed
Initiatives Planned: January to March 2012
Initiatives Planned: April to June 2012
Dodd-Frank Act: Statutory Dates For Actions
Initiatives Planned: April to June 2012

“Financial Company” Definition
The Board expects to request comment on a re-proposed rule to establish the standards for determining when a company is predominantly engaged in financial activities and qualifies as a “financial company.” (DFA Section 102(a)(6))

Real Estate Appraisal Requirements
The Board, along with other Federal regulatory agencies, expects to: (1) request comment on a proposed rule to implement appraisal requirements for higher-risk mortgages, and (2) issue final rules restricting acts and practices to ensure appraisal independence and to require reasonable and customary fees for independent appraisals. (DFA Sections 1471, 1472)

Real Estate Appraisal Management Company Registration and Reporting
The Board, along with other Federal regulatory agencies, expects to request comment on a proposed rule to establish minimum requirements for registration and reporting of appraisal management companies. (DFA Section 1473)

Residential Mortgage Appraisal Portability
The Board, along with other Federal regulatory agencies, expects to request comment on a proposed rule on residential mortgage appraisal portability requirements. (DFA Section 1472)

Real Estate Appraisal Automated Valuation Models
The Board, along with other Federal regulatory agencies, expects to request comment on a proposed rule to implement quality controls for real estate appraisal automated valuation models. (DFA Section 1473)

On Capitol Hill, the American Guild of Appraisers (AGA) is petitioning the Federal Reserve Board and the Consumer Financial Protection Bureau to overturn a recently adopted rule that stands in opposition to regulations contained in the Dodd-Frank Act.

The AGA wrote the organization’s plea based on the assertion that the Fed’s new rule poses a threat to “the viability of professional appraisal practice and undermines the legitimacy of real estate appraisals.”

The legislation in question was put in place last year by the Fed, and the regulation allows appraisal management companies (AMCs) to cut fees for appraisers. In its petition, the AGA stated that AMCs control up to 80 percent of the appraisal market and that, by allowing such companies to pay appraisers only a fraction of customary and reasonable fees, the law makes it possible for AMCs to offer fees that are nearly 50 percent below prevailing appraisal rates.

…continue reading the rest of this post: AGA Petitions Federal Reserve, CFPB