11th January 2012

ASA, NAIFA, AI, ASFMRA File Comments with Federal Reserve on Appraiser Independence; Seek Critical Change Regarding Customary and Reasonable Fees

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.”

Also addressed in the letter was the appropriateness of safe harbors for reliance upon third-party fee studies and surveys which rely on generally accepted survey methodologies, and a recommendation that the Fed, using its RESPA authority, require separate disclosure of appraisal fees and AMC fees in this or a subsequent rulemaking as a matter of consumer protection and to further ensure that appraisers receive customary and reasonable fees. The letter also directly addresses over a dozen questions raised by the Fed as part of the rulemaking process on a variety of issues, from the extension of conflicts of interest prohibitions to AVMs, to outcome-based appraiser compensation, to the consideration of professional designations as part of a determination of the reasonableness of fees.

http://www.appraisersnewsroom.org/?p=476

posted in Dodd-Frank C&R Topics | 3 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 | 0 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 | 0 Comments

27th January 2011

ASA, NAIFA, AI, ASFMRA File Comments with Federal Reserve to Seek Critical Change Regarding Customary and Reasonable Fees

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.”

…continue reading the rest of this post: ASA, NAIFA, AI, ASFMRA File Comments with Federal Reserve to Seek Critical Change Regarding Customary and Reasonable Fees

posted in Appraiser News | 0 Comments









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